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State v. Barnslater

1/23/2003

the trial court abused its discretion because none of the factors upon which the court based its dismissal of the charges indicate that the State's interest in prosecuting crime was outweighed by considerations involving fundamental fairness or the integrity of the judicial process.


Here, there were no allegations that Defendant was exposed to any unfairness as a result of the criminal proceedings against him. Similarly, nothing in the circuit court's written order evinces the need to dismiss these charges in order to ensure the integrity of the judicial process. Ultimately, the circuit court's decision to grant Defendant's motion was premised on its conclusion that the expenditure of money to assure Defendant's presence for sentencing and his possible incarceration in Hawaii represented a poor use of limited economic resources. In making this determination, the circuit court considered the gravity of the offenses committed by Defendant and the fact that, because he was incarcerated in Illinois, a lengthy period of time might elapse before Defendant could serve any sentence imposed on him in Hawaii.


Although we might agree with the circuit court that the State's limited resources might be better expended on other cases,judicial economy and justice were not implicated by the prosecution's decision to pursue this case. In exercising its inherent powers to administer justice, a trial court is required to respect the integrity and independence of other co-equal branches of government. Cf. State v. Augafa, 92 Hawaii 454, 470-71, 992 P.2d 723, 739-40 (App. 1999). If the prosecution wishes to expend significant amounts of money to repeatedly extradite a defendant in order to ensure that he or she is held accountable to the community for the crimes committed, it has the prerogative to do so. A trial court should exercise its discretion to dismiss an indictment only where the State's interest in prosecuting crime is outweighed by considerations of fairness to a defendant and the integrity of the judicial process. We believe the circumstances present in this case did not warrant, and cannot justify, the dismissal of the charges.


IV. CONCLUSION


Based on the foregoing, we vacate the First Circuit Court's March 8, 2001 order granting Defendant's motion to dismiss charges and remand this case for further proceedings.






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