Frohlich v. City Court

OPINION

DRUKE, Chief Judge.

¶ 1 A police officer arrested appellant Robert Frohlich for soliciting an act of prostitution, a misdemeanor,1 in violation of Tucson City Code § ll-28(l)(c). The officer prepared a written notice to appear and complaint in accordance with A.R.S. § 13-3903 and released appellant on his promise to appear in court. After he appeared, appellant moved to dismiss the complaint, arguing that the court lacked jurisdiction because the proceedings were commenced by notice and complaint rather than a “complaint under oath” in accordance with A.R.S. § 22-421. The court denied…