State v. Koch

When is a felony action commenced for purposes of the statute of limitation?

On May 9, 1983, a criminal complaint was filed in Spokane County District Court charging William Koch with first degree possession of stolen property on or about May 13, 1980. RCW 9A.56.150. A warrant was issued and Mr. Koch was arrested on May 10, 1983.

The information was not filed until June 3, 1983, more than 3 years after the alleged offense. Mr. Koch moved to dismiss, contending the action was barred by the statute of limitation and that the information was void because it failed to state limitation tolling…