Massey v. State

ELDRIDGE, Judge.

This criminal case presents the narrow issue of when the State must institute a prosecution for welfare perjury, a misdemeanor proscribed by Maryland Code (1957, 1985 Repl.Vol., 1989 Cum.Supp.), Art. 88A, § 62(a). More broadly, however, the case concerns the appropriate period of limitations for misdemeanor prosecutions generally.

The relevant facts are as follows. On September 9, 1987, the State filed a ten count criminal information against petitioner Denise Massey in the Circuit Court for Caroline County. Counts I through IV charged her with welfare perjury and were based on…