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How to File a Motion to Dismiss in a Criminal Case

A motion to dismiss can end your case entirely before trial — no jury, no verdict, no conviction. But it only works when specific legal grounds exist. Here's what those grounds are, how to write the motion, and what realistic expectations look like.

12 min read | Updated June 2026

What a Motion to Dismiss Does

A motion to dismiss asks the court to throw out the charges against you entirely, before trial begins. If granted, the case ends — you are not tried, not convicted, and the charges are gone. That's the best possible pretrial outcome.

But motions to dismiss in criminal cases only succeed on narrow, specific grounds. Unlike in civil litigation, where motions to dismiss for failure to state a claim are routine, criminal charges survive pretrial motion practice in the vast majority of cases. Courts apply a low threshold: if the indictment or information alleges facts that, if true, would constitute the crime charged, dismissal is not appropriate.

This doesn't mean you shouldn't file one. It means you need to identify a specific, recognized ground before you file — not a general argument that you're innocent or that the evidence is weak. Courts dismiss cases on legal grounds, not factual ones, at the pretrial stage. Factual disputes go to the jury.

Grounds That Actually Work

Speedy Trial Violation

The Sixth Amendment guarantees the right to a speedy trial. The federal Speedy Trial Act requires that federal defendants be tried within 70 days of indictment. Most states have analogous statutes with specific time limits. If the prosecution fails to bring your case to trial within the statutory period — and the delay is not attributable to defense requests for continuances — dismissal is the remedy.

What you need: Calculate the time from indictment or arraignment to your current date. Identify continuances that were granted at your request (those days are excluded). Check whether the total non-excluded delay exceeds the statutory limit. File the motion immediately when you identify a violation — courts can find waiver if you wait.

Double Jeopardy

The Fifth Amendment bars being tried twice for the same offense. If you were previously acquitted or convicted of the same charge, or if jeopardy attached in a prior proceeding that was dismissed on the merits, a subsequent prosecution is barred. Double jeopardy also covers lesser included offenses — you generally cannot be prosecuted for a lesser offense after acquittal of a greater one that subsumes it.

What you need: Evidence of the prior proceeding — the charging document, the verdict or order of dismissal, and the docket showing jeopardy attached. The motion must identify the earlier case, the charges, and why the current charges constitute the same offense under the Blockburger test.

Statute of Limitations

Criminal charges must be filed within the statute of limitations for the offense — typically three to five years for most felonies, one to two years for misdemeanors, with longer periods for serious offenses like murder. If the indictment or information was filed after the limitations period expired, the case must be dismissed.

What you need: The date of the alleged offense, the applicable statute of limitations under your state's code, and the filing date of the charges. If the charge was filed outside the window, the motion is straightforward — cite the statute, show the dates, move for dismissal.

Defective Charging Document

An indictment or information must allege all elements of the offense with sufficient specificity to notify the defendant of the charge and to prevent re-prosecution for the same conduct. If the charging document fails to allege an essential element of the offense, or is so vague that you cannot prepare a defense, dismissal may be warranted. Courts can also order the prosecution to provide a bill of particulars if the charging document is too vague.

What you need: Compare the elements of the charged offense (from the statute) to what the charging document actually alleges. If an element is missing or the allegations are incomprehensibly vague, move to dismiss. Courts often dismiss without prejudice on this ground, allowing the prosecution to re-file with a corrected charging document — but that costs them time and may cause Brady material to surface.

Outrageous Government Conduct / Entrapment

When government agents engaged in conduct so outrageous that prosecution would violate due process, courts have dismissed cases under the due process clause. This is a very high standard — courts have sustained it in cases where the government itself manufactured the crime, provided all the means and opportunity, and targeted a defendant who had no predisposition to commit the offense. Entrapment is normally a trial defense, but outrageous government conduct can support pretrial dismissal.

What you need: Specific documented facts showing the government's role in creating or instigating the offense, the lack of predisposition on your part, and why the conduct shocks the conscience. This ground rarely succeeds — courts are reluctant to dismiss cases on it — but in extreme factual situations it is a viable argument.

Prosecutorial Misconduct

Serious prosecutorial misconduct — presenting false evidence to a grand jury, knowingly eliciting perjured testimony, suppressing Brady material — can support a motion to dismiss, particularly if the misconduct infected the charging decision itself. Dismissal for prosecutorial misconduct is a severe remedy courts reserve for egregious cases, but it is recognized as a ground when the conduct was willful and prejudiced the defendant's ability to get a fair trial.

What you need: Concrete, documented evidence of the misconduct — not an allegation, but actual proof. Discovery materials, grand jury transcripts (where obtainable), prior judicial findings, or documented Brady violations. Courts do not dismiss based on accusations alone.

What Doesn't Work

Pro se defendants frequently file motions to dismiss on grounds that courts consistently reject. Filing these wastes your time and credibility:

"The evidence is insufficient to convict me." Sufficiency of the evidence is tested at trial (or on motion for acquittal after the prosecution rests), not on a pretrial motion to dismiss. Courts accept the allegations in the charging document as true for purposes of a pretrial motion.
"I didn't do it." Actual innocence is a defense for the jury, not a pretrial motion ground. A motion to dismiss is a legal argument, not a factual one. Courts will not evaluate the merits of your factual defense before trial.
"The officer lied in the police report." Credibility of witnesses is for the jury. If the officer's testimony is contradicted by evidence, that's cross-examination material, not dismissal grounds. An allegation that a report is false does not, standing alone, support dismissal.
Sovereign citizen or jurisdictional arguments. Arguments that courts lack jurisdiction over you based on common law citizenship, the UCC, admiralty jurisdiction, or similar theories are consistently rejected and can result in sanctions. They have no legal basis in any U.S. court.

Writing the Motion

A motion to dismiss follows the same basic structure as other criminal motions. Keep it concise and legally precise:

1
Caption and title — Court name, case number, parties, title: "DEFENDANT'S MOTION TO DISMISS FOR [GROUND]."
2
Introduction — One paragraph stating what you're asking for and the ground. "Defendant moves to dismiss the indictment on the ground that the prosecution is time-barred by the applicable statute of limitations."
3
Statement of facts — The specific facts that support the legal ground. For a speedy trial motion, this is a timeline. For double jeopardy, this is the prior case record. Be precise and cite documentary support.
4
Legal argument — The applicable constitutional provision or statute, the controlling case law, and your application of the law to the facts. Cite Supreme Court and circuit or state appellate cases. Keep this focused — one strong argument is better than five weak ones.
5
Conclusion and request for hearing — State what relief you're requesting: "Defendant respectfully requests that this Court dismiss the indictment with prejudice and requests an evidentiary hearing."
6
Certificate of service — Confirming you served the motion on the prosecution. Without this, many courts will reject the filing.

Use Brief to evaluate the ground before you file. Filing a motion to dismiss on a weak or legally unsound theory does more harm than good — it signals to the court that you don't understand the law, and it locks in a record that can be used against you. Upload your charging documents and case timeline to Brief to understand whether you have a viable dismissal ground before you write a word of the motion.

Know Before You File

Brief Identifies Whether You Have Viable Dismissal Grounds

Upload your charging documents and case timeline. Brief checks your case against the recognized grounds for dismissal — speedy trial calculations, limitations periods, charging document defects — and tells you what's worth filing before you invest time in a motion that won't succeed.

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Common Questions

Motion to Dismiss FAQ

Dismissal with prejudice means the charges are gone permanently — the prosecution cannot re-file. Dismissal without prejudice means the prosecution can re-file the same charges, typically by correcting the defect that caused dismissal (like a defective charging document). Always request dismissal with prejudice. Courts grant it when the dismissal ground is substantive — double jeopardy, statute of limitations, or outrageous government conduct — rather than procedural or technical.
Start from the date of indictment or arraignment (depending on your jurisdiction's rule). Count every day until the scheduled trial date. Then subtract "excludable time" — days that don't count against the clock because of continuances you requested, agreed-to delays, competency proceedings, or other reasons specified in the Speedy Trial Act or your state's equivalent. If the remaining non-excluded days exceed the statutory limit, you have a viable motion.
Yes, and often you should. Filing multiple pretrial motions is standard practice — a motion to dismiss on speedy trial grounds and a motion to suppress the search evidence, for example, can be filed simultaneously. Each motion addresses a different legal theory. Courts typically rule on pretrial motions in a single hearing. If the dismissal motion succeeds, the suppression motion becomes moot; if dismissal fails, suppression remains live.
The case proceeds to trial. But filing and losing preserves the issue for appeal. If you were convicted and the court incorrectly denied a speedy trial or double jeopardy motion, the appellate court can reverse. In some jurisdictions, denial of a double jeopardy motion is immediately appealable as a collateral order — you don't have to wait until after conviction to challenge it.
Yes, for most grounds. Pretrial motions must be filed by the court's deadline — usually 30 to 45 days before trial in state court. Some grounds, like speedy trial violations, may arise on a rolling basis as the clock ticks closer to the limit. Double jeopardy can be raised at any time, including after jeopardy attaches at trial. Statute of limitations and defective charging documents are typically waived if not raised before trial. File as early as you identify the ground.