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Commonwealth v. David Bradford  2 WAP 2011 (05/30/2012)

Topic: Constitutional Rights – Right to a Speedy Trial – Rule 600

Summary: The prosecution is permitted to rely upon the judicial system in its system for case tracking.  Therefore, if the judicial system errs in its case management and the prosecutor relies on the judicial system for its information, the prosecutor will not be faulted for speedy trial purposes.

Facts:  The Allegheny County Office of the District Attorney devised a case tracking method where its system at the Common Pleas level was not triggered until a case number was issued by the Court of Common Pleas.   However, at the time of the Bradford case, the Court of Common Pleas did not issue a case number until the case information was transmitted from the Magisterial District Court.  For reasons that remain unclear, the case information was not transmitted from the District Court to the Court of Common Pleas.  Therefore, the District Attorney’s Office’s case system was never initiated.  Defense counsel filed a motion to dismiss alleging that Bradford’s speedy trial rights were violated.  The trial court granted the motion.  The Pennsylvania Superior Court concluded that the trial court did not abuse its discretion by granting the motion.  The Pennsylvania Supreme Court disagreed and overruled the trial court.