State v. Stowe

BELL, Chief Judge.

In Massey v. State, 320 Md. 605, 579 A.2d 265 (1990), this Court considered, in the context of a prosecution for welfare perjury, the appropriate limitations period for misdemeanor prosecutions, and, in particular, those involving “penitentiary misdemeanors.” When that case was decided, the general statute of limitations for misdemeanors was contained in Md.Code (1974, 1989 RepLVol.), § 5-106 of the Courts and Judicial Proceedings Article. Pursuant to that section, except as it otherwise provided, “a prosecution for a misdemeanor not made punishable by confinement in the…