State of Connecticut v. Jon Swebilius

Summary

The court held that an arrest warrant issued within the statutory limitations period tolls the period only if executed without unreasonable delay, and that no categorical exception exists for brief delays. Once the defendant shows availability and nonelusiveness during the limitations period, the state must present evidence explaining why the delay was reasonable. The judgment was reversed and remanded for a hearing on the reasonableness of the thirty-two-day delay.