Court of Appeals Says Magistrate’s Order Does Not Toll Statute of Limitations

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The court of appeals held yesterday in State v. Turner, __ N.C. App. ___ (2016), that the issuance of a magistrate’s order charging a defendant with driving while impaired did not toll the two-year statute of limitations for misdemeanors. Because the defendant was not tried within two years of the offense, the appellate court ruled that the trial court properly dismissed the charges. This opinion is as big as surprise to criminal procedure experts as the outcome of last month’s presidential election was to pollsters. Does it mean that district courts must dismiss charges for misdemeanor offenses that occurred more than two years ago?

No – or at least not yet.  The North Carolina Supreme Court issued a stay yesterday, putting State v. Turner on ice for the moment.  While we wait to see what happens next, let’s take a look at what the court of appeals said in Turner.

Facts and procedural history. Turner was cited for driving while impaired on August 7, 2012. He was cited, arrested and brought before a magistrate for an initial appearance. After finding probable cause to believe the defendant committed the offense of impaired driving, the magistrate issued a magistrate’s order, which is the process required by G.S. 15A-511(c)(3).

On November 26, 2014, Turner moved to dismiss the charges on the basis that the statute of limitations had expired. The district court judge agreed, and a superior court judge affirmed that determination.The State appealed from the dismissal of the charges.

Court’s analysis. The court of appeals noted that G.S. 15-1 sets forth the statute of limitations for misdemeanors. The statute, which has not been amended since 1943 and thus pre-dates the creation of district court, requires that “all misdemeanors except malicious misdemeanors [] shall be presented or found by the grand jury within two years after the commission of the same, and not afterwards . . . .”  The court then proceeded to consider two state supreme court cases construing the provision.

State v. Hedden, 187 N.C. 803 (1924). The state supreme court in Hedden held that a warrant issued by a magistrate charging the defendant with abandonment of his wife and children did not toll the statute of limitations. The defendant in Hedden was tried for the offense in superior court based upon an indictment issued more than two years after it occurred. The supreme court held this was error, and that the defendant’s motion to dismiss should have been allowed. The court reasoned that G.S. 15-1 had “no saving clause . . . as to the effect of preliminary warrants before a justice of the peace or other committing magistrate, and . . .  the law must be construed and applied as written.” Id. at 65. Thus, the court concluded that there “must be a presentment or indictment within two years from the time of the offense committed and not afterwards.” Id.

State v. Underwood, 244 N.C. 68 (1956). Hedden was revisited decades later in State v. Underwood, 244 N.C. 68 (1956). Underwood was charged with impaired driving in a warrant issued by the clerk of a county recorder’s court. He was found guilty and appealed to superior court, where he argued that the statute of limitations barred his prosecution as the alleged offense occurred more than two years earlier and no indictment or presentment had been found by the grand jury. The superior court rejected his argument, and Underwood was tried and adjudged guilty. He appealed. The state supreme court affirmed his conviction, holding “that in all misdemeanor[] cases, where there has been a conviction in an inferior court that had final jurisdiction of the offense charged, upon appeal to the superior court the accused may be tried upon the original warrant and that the statute of limitations is tolled from the date of the issuance of the warrant.” Id. at 70. The Underwood court distinguished Hedden on the basis that the defendant there could not have been tried in superior court upon the original warrant.

Back to Turner. The court of appeals stated that “[i]n the roughly sixty years since Underwood was decided, that case has only been held to apply to indictments, presentments, and warrants; never once has it been applied to citations or other forms of criminal pleading.” The court then said that G.S. 15-1 was explicit in requiring that an indictment or presentment be issued within two years. Plus, the court noted that Hedden said the statute had to be applied as written.

The court then held that the “issuance of a citation did not toll the statute of limitations.” Because the State did not prosecute Turner in two years, it was barred from proceeding.

Was it a citation or a magistrate’s order? The court of appeals in Turner repeatedly refers to the charging document as a citation. Yet the opening paragraph of the court’s opinion states that the citation was converted into a magistrate’s order. A magistrate’s order is the functional equivalent of a warrant for arrest issued after a defendant has already been arrested. It is not clear why a warrant for arrest would operate to toll the statute of limitations period but a magistrate’s order would not.

Even if Turner had been charged by citation alone, I’d still find the opinion surprising.

Up until now, I understood “the critical date for purposes of determining whether the statute of limitations has run [to be] the date on which a defendant is properly charged with committing a criminal offense.” State v. Taylor, 212 N.C. App. at 249–50 (2011). That’s the language the court used in dicta in Taylor, and it comports with the manner in which Chapter 15A permits misdemeanor offenses to be charged.

How would Turner impact defendants charged with misdemeanors? If Turner becomes law, many defendants will benefit initially from the dismissal of misdemeanor charges that have been pending for more than two years. In the longer run, however, many defendants who otherwise would have been cited and released could wind up with arrest records. That’s because the State is likely to seek issuance of a warrant for arrest rather than rely on a citation that does not toll the statute of limitations.

Of course, if the General Assembly doesn’t approve of the outcome in Turner, it can re-write G.S. 15-1 to carry out its intent for future cases. Perhaps it is time for a remodel anyway. It has been a while since the last update.

26 comments on “Court of Appeals Says Magistrate’s Order Does Not Toll Statute of Limitations

  1. SOG – Please give us prosecutors more guidance to prepare for the contingency that the supreme court affirms. Should we seek presentments on old DWIs? It doesn’t seem that an appeal de novo from district to superior would toll the statute of limitations – is it possible to seek a warrant, presentment, or indictment post-appeal? Please help.

  2. The “first” holding in Turner indicated that Underwood was limited to situations where a defendant has appealed a conviction in an inferior court for a trial de novo. Turner does clear up, to some extent, the troublesome use of the word “warrant” in Underwood. Hedden and Underwood do not, and never did, stand for the proposition that an arrest warrant (or any other criminal process) tolled the statute. In fact, Hedden specifically rejects that notion that “preliminary warrants” toll the statute of limitations. Accordingly, it is difficult to see how an arrest warrant, magistrate’s order, statement of charges or citation can toll the statute. Perhaps a better way to look at it is that the statute of limitations cannot be tolled while the case remains in district court. It must either be in Superior Court via an indictment or a de novo appeal. The “second” holding of Turner then is a fairly straightforward reading of 15-1, which the court appropriately indicates is unambiguous. It is also of great significance that since 15A-921 and 922 where enacted the language of 15-1 has never been changed to indicate that the issuance of those specified charging documents toll the statute. Rules of statutory construction would thus dictate that the legislature did not intend for those types of charging documents to toll the statute, only to initiate a prosecution in district court for resolution prior to the expiration of the 2 year limitation period.

  3. “Does it mean that district courts must dismiss charges for misdemeanor offenses that occurred more than two years ago? No – or at least not yet. The North Carolina Supreme Court issued a stay yesterday, putting State v. Turner on ice for the moment.”

    Why do you say this? The Court of Appeals has cited cases that were stayed and pending in the Supreme Court at the time of their citation several times over the years. If the Court of Appeals considers stayed cases good authority, so should trial courts across the state.

    • State v. Hartley, 212 N.C. App. 1, 12 , 710 S.E.2d 385, 396 (2011) (citing State v. Hurt, __ N.C. App. __, __, 702 S.E.2d 82, 99, temporary stay allowed, 365 N.C. 80, 705 S.E.2d 349 (2010)).

    • State v. Jones, 216 N.C. App. 519, 526, n.3, 718 S.E.2d 415, 421, n. 3 (2011) (citing State v. Williams, __ N.C. App. __, __, 702 S.E.2d 233, 238, temporary stay allowed, 365 N.C. 82, 365 N.C. 399, 705 S.E.2d 382 (2010)).

    • State v. Garnett, 209 N.C. App. 537, 541-42, 706 S.E.2d 280, 283 (2011) (citing State v. Jones, 208 N.C. App. 734, 736, 703 S.E.2d 772, 774, (2010) (citation omitted), temporary stay allowed, 365 N.C. 70, 365 N.C. 187, 705 S.E.2d 385 ( 2011).

    And most recently, State v. Ward, COA16-52 (Nov. 1, 2016) (citing State v. Floyd, 238 N.C. App. 110, 766 S.E.2d 361(2014), review allowed, writ allowed, ___ N.C. ___, 771 S.E.2d 295 (2015).

    (h/t to Danny Spiegel for these cites)

  4. My bigger question is why is the institute of government so pro-law enforcement; it seems every time the court rules for the defendant; Ms. Denning and a lot of her co-workers will do everything in their ability to make sure they have a work around for law enforcement or that the judges were wrong and they misapplied the law in that case. HEY INSTITUTE OF GOVERNMENT the burden is always on the government; Why don’t some of you guys come off your high horses up in academia world and come down into the real world and try some cases to see just how unfair almost every trial is for the defendant!!!!!!!!! Matter of fact I had a judge call you guys and ask a question about a motion i filed in a case during a lunch break; after the lunch break the judge, told me he/she was shocked when people from the institute were upset because they could not find a case that ruled for the state–WTH.

    • They’re not pro law enforcement. This case is a complete reversal from common practices for decades so it’s a bit of a shock. Also in a lot of motions there are mixed results, some pro defense some pro prosecution so that’s probably why they were surprised.

      • “Of course, if the General Assembly doesn’t approve of the outcome in Turner, it can re-write G.S. 15-1 to carry out its intent for future cases. Perhaps it is time for a remodel anyway. It has been a while since the last update.” Yes, very neutral in her analysis.

    • Are you kidding me? Did you really state that the trials are “state” sided? Have you ever tried a case? The burden is on the Government, in every case. I just seem to only hear the defense whining when every decision made by the court goes your way. One thing should be clear, in almost every case. And that is this: If your clients did not break the law in the first place, you would not have to look for a loop hole to get them out of it.

      • Jon, I’m assuming that in your opinion everyone who is charged with a crime, “broke the law”. That’s why us lawyers have to look for loopholes? What loophole does the Constitution fall under? What about Court procedure? Is that a loophole too. I understand if you trust the government unconditionally and know that they would never charge someone for politically motivated reasons or any other improper purpose! I also understand that your philosophy is “if you don’t break the law, you don’t have anything to worry about”. If you don’t mind, maybe shoot me your home address and I’ll call in an anonymous tip to your local police agency and let them do a “knock and talk” at your home. Maybe your wife and kids will be there when this happens and of course if you don’t have anything to hide, you can simply let these 4-5 armed gentlemen in your home to go through your personal items and conduct a thorough search. Just a friendly tip, you might want to make sure you don’t have any expired prescription medicine bottles lying around or ones where the label has worn off or otherwise been removed, or have any of your different meds in the same bottle for convenience. Also, if you smoke tobacco, may want to make sure you don’t do it with a pipe, or anything other than a cigarette in the manufactures container. Those types of things can often be misinterpreted as paraphernalia. If you do happen to have some expired medication for which you no longer have an active prescription, do yourself a favor and request that law enforcement weigh the pills instead of counting them. This way you can assume full responsibility for the substance you possessed (and likely transported). If you need any help once you are charged, I’d give you my number, but you’d probably be better off if you just went to the local DA and got his advice on how to proceed.

        • Blair that was a great statement to Jon

      • I have represented many clients who did not “break the law in the first place”. Also, it is a bit asinine to say that holding the state accountable to the rule of law and criminal procedure is just looking for a loophole.

  5. It is doubtful that the holding in Turner will affect any great number of cases. If the State is concerned with a citation reaching its “expiration date”, the State can issue a Misdemeanor Statement to cure the problem. The court so stated in State v. Madry. The State, in almost all situations, controls the speed at which a case is prosecuted. There should be great concern when a case approaches the time limit. The holding should come as no surprise to those familiar with the basic rules of statutory construction. The surprise may come from the fact that the court actually applied the rules of construction to the plain language of the statute and reached what is the correct result when these two facets are considered, especially when it was DWI case.

    • “The State can issue a Misdemeanor Statement to cure the problem. The court so stated in State v. Madry.” I don’t agree with this reading of Madry. Madry cited Hundley, which cited Underwood, which is about warrants.

  6. The NC Supreme Court has issued a temporary stay in Turner: https://appellate.nccourts.org/orders.php?t=P&court=1&id=325128&pdf=1&a=0&docket=1&dev=1

  7. Most od the defense attorneys in my area use the art of “continuance” in order to give their clients time to pay for their services. With this decision, I can really see every defense attorney pushing to continue cases. Another issue is the backlog of blood samples sitting at the state lab. What a way to get out a criminal offense.

  8. Let’s assume, for the sake of argument, that defendants are actually innocent until proved otherwise. Imagine the indignity of arrest, the expense and trouble of multiple court dates to ask for justice, forced on an innocent person. Our citizens, our neighbors,our community. Let’s treat them with a little more dignity and respect for the legal presumption that they are entitled to. Two years is a very long time for an innocent person to wait. I’m glad the SOL is finally getting some teeth.

  9. The statement that the NCSC stay has the effect of “putting State v. Turner on ice for the moment” appears to be incorrect, or least, calls for explanation. A temporary stay has the effect of preserving the status quo between the parties. See N.C. R. App. P. 23(e) (“temporarily staying enforcement or execution of the judgment, order, or other determination”). The precedential significance of the opinion remains unless and until it is overturned by a higher court. See Hunnicutt v. Griffin, 76 N.C. App. 259, 332 S.E.2d 525, review denied, 314 N.C. 665, 336 S.E.2d 400 (1985) (“When [the opinion] was filed on the morning of 2 February 1984 at 11:24 a.m., it became the law in North Carolina. It is elementary that a case becomes binding authority upon filing . . .”), citing, State v. Riven, 299 N.C. 385, 261 S.E. 2d 867 (1980). The Court of Appeals routinely relies upon its own prior decisions as controlling authority, even when a temporary stay was in place pending further review by the Supreme Court. See, e.g., David v. Ferguson, 153 N.C. App. 482, 485, 571 S.E.2d 230, 232 (2002). If the decision relied upon is subsequently overruled, the Court of Appeals may have to reconsider, see, e.g., David v. Ferguson, 357 N.C. 452, 583 S.E.2d 594 (2003), but until it is overruled, the Court of Appeals has no option but to adhere to it. In re Civil Penalty, 324 N.C. 373, 384, 379 S.E.2d 30, 37 (1989) (“Where a panel of the Court of Appeals has decided the same issue, albeit in a different case, a subsequent panel of the same court is bound by that precedent, unless it has been overturned by a higher court.”)
    These authorities indicate that State v. Turner is the law in North Carolina, binding upon any trial court judge before whom a dismissal motion is brought, unless and until it is overturned by the Supreme Court, notwithstanding the temporary stay. A suggestion to the contrary requires explanation in light of the fact that prosecutors and judges may rely upon the guidance offered here.

    • Thanks, Paul, for your comment. Here is why I think the opinion is not binding precedent at the moment.
      While the court of appeals has relied upon cases in which a temporary stay has been granted, I’m not aware of a case in which the court addressed the effect of the stay or expressly indicate that it was bound by those decisions. In State v. Isenhour, 194 N.C. App. 539, 544 n.1, in contrast, the court characterized the defendant’s reliance upon an earlier court of appeals’ plurality decision as “misplaced since our State Supreme Court has recently stayed the Court of Appeals’ decision pending appeal.”
      Moreover, it strikes me as incongruous to conclude that the holding in Turner does not apply to the defendant in that case, but does apply to other defendants in his circumstance.
      Interestingly, the state of Michigan, unlike North Carolina, has two types of stays. One stays the precedential value of the opinion. The other stays the decision itself. See, e.g., People v. Uphaus, 733 N.W.2d 21 (Mich. 2007). North Carolina does not have that sort of procedure. This, I think, lends support to the idea that a stay stays both aspects of the opinion.
      If we were in Alabama, the rule would be different. The Alabama Supreme Court held in Grantham v. State, 540 So.2d 779, 780-82 (Ala. 1988), that a stay did not prevent a decision of the court of criminal appeals from having value. As a result, the Grantham court deemed the defendant to have constructive notice that his absconding from a supervised probation program constituted the criminal offense of escape.
      The express statement in Isenhour, the issuance of a stay in Turner even before the mandate was issued, and the lack of any formal mechanism to seek a stay that addresses precedential value, lead me to conclude that trial courts are not bound by Turner.
      That said, trial courts may find the reasoning in Turner persuasive and rule accordingly.
      Regardless of whether we ultimately agree on every issue, I appreciate your use of this forum for posing challenging questions and engaging in thoughtful debate.

      • Shea, Thanks for your response to my post. We may or may not disagree as to what the law ought to be, but I trust we can agree that Isenhour says what it says, as does Honeycutt (quoted in my post), and David v. Ferguson (cited in my post), from which the following quote is taken:

        Based on binding authority established in Rosero v. Blake, we find that the trial court committed error in applying the best interest test to our case facts. Rosero v. Blake, 150 N.C. App. 250, 563 S.E.2d 248, temporary stay allowed, 355 N.C. 751, 565 S.E.2d 670, [***6] review allowed, writ allowed, 356 N.C. 166, 568 S.E.2d 610, 2002 N.C. LEXIS 712, 2002 WL 2005421 (2002).

        Note that the Court of Appeals based its holding in David v. Ferguson upon the principle that a case formally stayed by the N.C. Supreme Court was “binding authority.” Likiewise, whereas your post implies Turner has no immediate effect (“If Turner becomes law,”) the Court of Appeals has held, “When [the opinion] was filed on the morning of 2 February 1984 at 11:24 a.m., it became the law in North Carolina.”

        For reasons that you explain, you favor Isenhour’s statement that an appellant’s reliance on a stayed opinon was “misplaced.” That’s fine – you say tomato, I say tomahto – but your posting that the stay “put[] State v. Turner on ice” comes across as a definitive statement of what the law is, when it is really just a statement of the law as you think it ought to be. Isenhour’s approach might or might not the best, but it is the only N.C. authority you cite, it’s dictum, and it is contradicted by other authority that I cited, where the binding character of a stayed opinion was not dictum but essential to the holding.

  10. The suggestion that the police may decide to make an arrest rather than issuing a citation where they would otherwise have been satisfied that the arrest was unnecessary because of a concern that the State cannot complete the prosecution of a misdemeanor charge within two years is deeply troubling to me!
    Do you know what happens when a 2+ year old misdemeanor is dismissed?… Nothing. What happens when these cases take forever to get to jury trial? People lose jobs from coming to court so often. It is an embarrassment, our lack of true criminal procedure in NC. The first footnote in Doggett cites LaFave to suggest that presumptive prejudice may begin to develop prior to 1 year. And that is post-accusation delay.
    This is cheesecake.
    By the way, what says a stay makes an appellate decision not law yet? The stay as I understand it applies to that case. Meaning the actual case is not over, because the Supreme Court may take it up. Fine. That doesn’t mean a trial judge does not have to follow a published Court of Appeal opinion does it? Maybe I’m wrong. I thought appellate courts opinions become not the law when they are actually reversed.

  11. Hey Ms. Denning, Can we get some unbiased commentary, at least in the first paragraph? Who are the criminal procedure experts to whom you refer? Why is it such a “Big Surprise”? Did these experts read the history of case law cited in Turner, before they declared their surprise or astonishment at such a novel concept? It is disappointing that attorneys like me who go to court everyday and argue constitutional and statutory issues have to read commentary from “experts” about how surprising it is. My colleague, Mr. Rohr, who did the Turner appeal and I have been arguing these Statute of Limitations issues for over 3 years now. Mr. Rohr has even presented on this very issue at CLEs sponsored by NCAJ. I guess the experts who were “surprised” didn’t go to those CLEs, nor did they bother to have a conversation with lawyers who were making these arguments at the trial level. Probably too busy planning their next lecture. They also likely didn’t read the case law which was cited and referenced in the Turner Brief. If they had, maybe their “surprise” wouldn’t have been quite as BIG as you claim. Just go ahead and in your next post or “educational” opportunity to our judges around the State, tell them that the “Experts” endorse a police state. That the constitution is really second fiddle to what the legislature tells us and that criminal procedure is a matter best left to the legislature, law enforcement and district attorneys, and not judges. In fact, why don’t we save some money and get rid of our judges. We will let law enforcement, prosecutors and Experts tell us what the law is. The decision in Turner is NOT a novel legal theory that some liberal appellate judges stumbled across while meandering down the criminal justice path. Those like yourself who are in a position where people are inclined to listen should not only give thought to what they say and their opinions on the matter, but how they say it. The only Expert I’m inclined to defer to in the Turner matter are the 3 Experts who unanimously agreed.

  12. The statement that the NCSC stay has the effect of “putting State v. Turner on ice for the moment” appears to be incorrect, or least, calls for explanation. A temporary stay has the effect of preserving the status quo between the parties. See N.C. R. App. P. 23(e) (“temporarily staying enforcement or execution of the judgment, order, or other determination”). The precedential significance of the opinion remains unless and until it is overturned by a higher court. See Hunnicutt v. Griffin, 76 N.C. App. 259, 332 S.E.2d 525, review denied, 314 N.C. 665, 336 S.E.2d 400 (1985) (“When [the opinion] was filed on the morning of 2 February 1984 at 11:24 a.m., it became the law in North Carolina. It is elementary that a case becomes binding authority upon filing . . .”), citing, State v. Riven, 299 N.C. 385, 261 S.E. 2d 867 (1980). The Court of Appeals routinely relies upon its own prior decisions as controlling authority, even when a temporary stay was in place pending further review by the Supreme Court. See, e.g., David v. Ferguson, 153 N.C. App. 482, 485, 571 S.E.2d 230, 232 (2002). If the decision relied upon is subsequently overruled, the Court of Appeals may have to reconsider, see, e.g., David v. Ferguson, 357 N.C. 452, 583 S.E.2d 594 (2003), but until it is overruled, the Court of Appeals has no option but to adhere to it. In re Civil Penalty, 324 N.C. 373, 384, 379 S.E.2d 30, 37 (1989) (“Where a panel of the Court of Appeals has decided the same issue, albeit in a different case, a subsequent panel of the same court is bound by that precedent, unless it has been overturned by a higher court.”)

    These authorities indicate that State v. Turner is the law in North Carolina, binding upon any trial court judge before whom a dismissal motion is brought, unless and until it is overturned by the Supreme Court, notwithstanding the temporary stay. A suggestion to the contrary requires explanation.

  13. Paul Green cites NC case law. The IOG representative cites one inapplicable footnote and how the issues of a stay are addressed in Alabama and Michigan. I would hope that the IOG rep would consider referencing the opportunity of the legislature to address how a stay would be treated, much like the reference contained in blog of surprise regarding the ruling, versus creation of unsupported arguments designed to impede and prevent actual application of Turner as it now stands. There doesn’t ever seem to be the same brainstorm of sole rational thought that is supportive of contentions regarding overreaching of enforcement or intrusion of rights.

    There is little doubt that the NC Supreme Court will likely overturn this ruling as it has repeatedly done over the last several years in multiple rulings that have favorably impacted accused individuals in our state. It is disappointing at best, curious at midsection and certainly gives legitimate cause for actual concern over what can be fairly suggested as a well established circumstance of support by certain authors at the IOG for those with law enforcement authority in NC. The possibility of use of this pulpit for an appearance of educated and informed opinion provision that may actually have an underpinning of partisan misuse is disturbing. Such would be contrary to what one must assume is an effort directed at balanced information dissemination and not an a commitment to specified influence of those assigned to uphold the ideals and foundation of our state’s laws & constitution as well as our country’s constitution. Certainly all citizens, even those accused of crimes, deserve a neutral respondent within the government approved intelligentsia.

    It’s sad to believe this but it becomes increasingly difficult to conclude anything other than support for “the means justify the ends” and a sufficient pedigree to know how to advance that line of thinking is how at least one representative of our official state governmental educational entity, which puts forth stated values as “nonpartisan” and “policy-neutral,” operates.

    The stayed opinion is good law and the IOG knows that. You can bet the stay of an opinion providing cause to search or suspicion to detain would likely be cited in a fact specific situation to prosecutorial authorities as good law for use in supporting contentions regarding the same. Of that, I’m truly sorry, I have no reasonable doubt.

  14. “A magistrate’s order is the functional equivalent of a warrant for arrest issued after a defendant has already been arrested. It is not clear why a warrant for arrest would operate to toll the statute of limitations period but a magistrate’s order would not.”

    I don’t think North Carolina had any Magistrates Orders to construe before 1973. What is most surprising are the decades and decades of lawyers who believed it futile to make the same point as was made in Turner.

  15. Does an order for arrest for a failure to appear toll he statute? I would guess yes?

  16. […] Last month’s blog commentary included a lively dispute about whether trial courts are bound to follow Turner given the state supreme court’s issuance of a stay. Regardless of whether Turner is binding precedent (and I don’t think it yet is, given the stay), trial courts may rely on its reasoning.  Moreover, the state supreme court may ultimately decline to review the opinion or, if it does grant review, may affirm its holding. Thus, prosecutors across the state are considering whether and how the State may satisfy or toll the statute of limitations for misdemeanors charged by citation or magistrate’s order. […]

  17. […] Greensboro DWI attorneys seek court approved dismissals after Court of Appeals ruling in State v. Turner. […]

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