California Supreme Court
Steen v. Appellate Division, Super. Ct.
August 11, 2014
Summary
The court denied a writ petition challenging a misdemeanor complaint that a superior court clerk electronically generated for failure to appear. It construed the governing statute to permit clerks to generate such complaints only with prosecutorial approval, and held that the Los Angeles City Attorney had implicitly approved the practice in advance without violating separation of powers or due process. Because the complaint was valid when filed within the limitations period, the conviction was not time-barred.