State v. Butler

Summary

The court held that a criminal trial court loses subject matter jurisdiction when it enters a final and unconditional dismissal of all pending charges, even if the state moves to reopen the judgment within four months. The civil four-month rule does not apply to criminal judgments, and the court overruled the contrary portion of an earlier decision. The court declined to decide whether a fraud-based exception could permit reopening because the record did not support a finding of intentional or material misrepresentation.