State v. Juan F.

Summary

The court affirmed the defendant’s convictions, holding that his arrest warrant tolled the applicable statute of limitations because he failed to prove that he was available for arrest during the sixteen-year period before the warrant was executed. The trial court’s finding of unavailability was supported by evidence that the defendant relocated to Puerto Rico, lived there largely off the grid, and did not provide information that would facilitate his apprehension. Because the defendant failed to establish availability, the burden never shifted to the state to explain the reasonableness of the delay.