Funk v. Commonwealth

Opinion

BARROW, J.

The defendant appeals from a conviction for escape from jail. We hold that his right to a speedy trial under Code § 19.2-243 required that he be tried within five months after he was detained in Virginia following indictment even though he was detained in a different jurisdiction from that in which his charge was pending.

The defendant escaped from the Fauquier County jail on December 12, 1988. He was arrested in Pennsylvania on March 29, 1989, and incarcerated there for three charges of larceny committed in Pennsylvania. The defendant pleaded guilty to the larceny charges and…