Manslaughter Statute of Limitations In Guam
In People v. Quinata, 785 F.2d 812 (9th Cir. 1986), the defendant was charged as an adult for manslaughter, although he had turned eighteen (18) the day after the death.
The court dismissed the case against him as he was not an adult at the time of the alleged crime. Id. at 813. a petition was then filed in the Juvenile Division. Id. the defendant made a motion to dismiss because he was no longer a juvenile. Id. on appeal, the Appellate Division reversed. Id.
The defendant then appealed to the Ninth Circuit and the case was affirmed. Id. Upon remand, the People moved to certify Quinata to be tried as an adult. Id. the motion was granted; however, Quinata then appealed claiming a violation of the statute of limitations. Id.
The court found that the petition in Juvenile Court stated the essential facts and was signed by the prosecuting attorney. Id. at 814. Therefore, the court concluded that the petition, filed approximately a month after the death occurred, although not labeled a complaint, met the definition of a complaint and was timely filed. 13 Id. at 814.
"A petition in the Juvenile Division, like a complaint or indictment in the Adult Division, is meant to inform the defendant of the offense the state accuses him of having committed." Id. at 813. the Ninth Circuit also makes a reference to complaints and indictments being alike. Id.
The reasoning behind the Quinata decision is clear. the court looked to the definition of a complaint and found the petition satisfied that definition. This court was result oriented in that it made reference to the fact that "were [the court] to accept appellant's argument, a juvenile offender like Quinata could go free by pursuing numerous motions and appeals to delay the prosecution." Id. at 814.
The People argue that the holding in Quinata does not speak to prosecutions as envisioned by 25.30 nor does it provide for dismissal of a case not filed under 25.30.
This may be true, however, we may look to Quinata in our determination of whether an indictment can be construed as a complaint under the current statutory scheme.
All consequences which flow from that determination may or may not be part and parcel of the determination itself. Unquestionably more work is involved in prosecuting a felony; however, this does not mean that statutory limitations should be ignored in order to give the People an additional time.