State v. Butler

Summary

The court affirmed the judgment barring the trial court from reopening the defendant’s unconditional dismissal after he completed a supervised diversionary program. It held that the civil four-month rule does not apply to criminal judgments and that dismissal of all criminal charges eliminates the charging document that supplied the trial court’s jurisdiction. The court declined to decide whether a criminal dismissal could be reopened for fraud because the record did not establish intentional or material misrepresentation.