On October 26, 2026, newspapers in Chile carried a ruling from the Valparaiso Court of Appeals that took a conviction away from a man who had confessed. Hugo Bustamante Perez was already serving the most severe sentence Chilean law allows, for the 2020 murder, with other charges, of a sixteen-year-old girl. In 2024 he had told a journalist the names of two more people: Elena Hinojosa and her son, Eduardo Paez, whose fate had been unknown to their family since 1996. A judge in Villa Alemana convicted him of both killings in January 2026. The appeals court did not say that the judge had the wrong man. It said the state had waited too long.
That is the strange power of a statute of limitations. It does not ask whether a crime happened or who committed it. It asks what day it is. In many legal systems even homicide has carried such a deadline, and when the deadline passes the law treats the case as if a door had closed. Prosecutors can know the facts and families can know the name. A defendant can admit everything, and none of it matters once the period has run.
The cases that follow come from Chile, France, Sweden, Russia and the United States. In some the clock ran out before anyone was charged; in others a defendant reached for it in the middle of an appeal. In one, an American court used a limitations argument to declare that for murder there would be no clock at all.
Eduardo Miguel Paez Hinojosa was 27 in 1996, and his mother, Elena Isabel Hinojosa Cena, was 55, according to BioBioChile and Meganoticias. Their family filed what Chilean law calls a report of presumed misfortune. An inquiry was opened and later archived without result. For almost three decades the family did not know what had happened to them.
Bustamante had by then built a record that would make him one of the most discussed prisoners in the country. In January 2005, in the same town, he killed his former partner, Veronica Vasquez, 49, and her nine-year-old son, Eugenio. The oral criminal court of Vina del Mar sentenced him to 12 years for one killing and 15 for the other, 27 years in all. He was paroled in April 2016 after about 11. In December 2021 a court in Vina del Mar sentenced him to presidio perpetuo calificado for the July 2020 murder, with other charges, of Ambar Cornejo, 16, the daughter of his new partner, and the Supreme Court confirmed the sentence in June 2022.
The journalist Ivonne Toro Agurto met him six times at the Rancagua penitentiary between June 2023 and January 2024 while she worked on a book about Ambar. In one conversation, as El Mostrador and 24horas later reported, he told her he had a gift for her and gave her two names: Eduardo Paez and his mother. The gift, he explained, was that the case had never been solved. CIPER published her report on June 6, 2024. Prosecutors confirmed the identities of the two victims on September 2, 2024.
From that point the question was no longer who. It was when, and under which law. In March 2025 the Villa Alemana chief prosecutor, Osvaldo Basso, said the evidence placed the deaths at the end of June 1996, so the case belonged to the old criminal procedure, since the reformed courts in Valparaiso handle only cases from 2003 onward. He described the killings as aggravated homicides and argued that the limitation period had been interrupted by the 2005 killings, so the case was still alive. On January 30, 2026, Judge Javiera Opazo Vaccaro of the Juzgado de Letras de Villa Alemana agreed that he was guilty. She convicted him of two aggravated homicides committed on June 27, 1996, arising from a dispute over money he owed Paez, and imposed a single sentence of ten years and a day.
The Valparaiso Court of Appeals read the same file differently. It held that treachery had not been proved and reclassified both killings as simple homicides, which carry a ten-year limitation period. According to G5noticias, which quoted the ruling, the court accepted that the period had restarted with the January 2005 killings. But a restarted clock still runs, and by the court’s count it ran out in January 2015. The 2020 murder of Ambar Cornejo, it held, could not interrupt a period that had already expired, and the 2024 investigation could not revive what the law had extinguished. It declared the criminal action extinguished and ordered a sobreseimiento definitivo, a final dismissal. Justice Rafael Corvalan Pazols drafted the ruling.
The family’s lawyer, Jose Ignacio Tapia, argued that every later conviction should have set the count back to zero. The family asked the Supreme Court to annul the appeals ruling and restore the conviction. As of October 26, 2026, that appeal was pending. The dismissal changed nothing about Bustamante’s life sentence. It changed only whether the law would ever say, in a judgment that stands, that he killed Elena Hinojosa and her son.
The idea that time can shelter a homicide is not new, and one of its most complete demonstrations took place in Brittany more than 170 years ago.
Hélène Jégado was born on June 17, 1803, at Kerhordevin, in the commune of Plouhinec in Morbihan, to a farming family. In the late spring of 1833, at about 30, she was hired as cook at the presbytery of Guern by the priest, Joseph Le Drogo. Within about four months seven people in that household died, among them the priest and Jégado’s own sister, Anna. Over the following years she worked in a string of Morbihan towns, from Bubry and Locminé to Auray, Pontivy, Hennebont, Lorient and Ploemeur, and deaths followed her from house to house. At Locminé in 1835 members of the Toussaint family died. At Ploemeur in 1841 a little girl, Marie Brégé, not yet three, died in the household of her grandparents, where Jégado was working. At the time, the Archives départementales d’Ille-et-Vilaine note, none of those deaths was suspected to be poisoning.
She was arrested in Rennes on July 1, 1851, the day Rosalie Sarrazin died. When officials made inquiries in Morbihan, word spread that a servant named Hélène had been arrested, and the court at Pontivy warned the procureur général at Rennes of local talk linking a servant of that name to old, unexplained deaths. Investigators traced her through some 18 years of service. The court’s own estimate, as the archives record it, was that 37 people had been poisoned and 23 had died.
Almost none of those deaths could be charged. French law then set a limit of ten years for the prosecution of crimes, and every death in Morbihan was older than that. The indictment that went before the Ille-et-Vilaine assizes in December 1851 covered only Rennes: the murders of Pérotte Macé, Rose Tessier and Rosalie Sarrazin, four attempted murders and 11 thefts, 18 counts in all.
The older deaths still entered the courtroom, by another door. The prosecution called witnesses from Morbihan in the first days of the trial, not to prove crimes it could no longer charge but to show the jury who she was. Dr Toussaint, a physician from Locminé who had treated the victims there, his own relatives among them, gave detailed testimony. A surviving man from the Toussaint household described the revulsion that had kept him from accepting anything from her. In the curators' words, the Morbihan facts were known and weighed against her, although none could be the subject of a verdict.
On December 14, 1851, the jury returned guilty verdicts on all 18 counts with no mitigating circumstances, and she was sentenced to death. The Cour de cassation rejected her appeal on January 16, 1852. Louis-Napoléon Bonaparte refused a pardon on February 22, and she was guillotined at Rennes early on February 26, 1852. The law had executed her for three deaths. The other twenty, by the court’s own count, belonged to a period the law had already let go.
The limitation clock also shaped one of the most damaging judicial failures in modern Scandinavia, though in that case its effect ran in more than one direction.
Sture Bergwall, born in Falun in 1950, was committed to closed forensic psychiatric care in 1991 after convictions for theft and robbery, and held at Säter Hospital in Dalarna. There, in therapy and later to police, he began to confess to killings. He took the name Thomas Quick. Between 1994 and 2001 six district courts convicted him of eight murders in Sweden and Norway, and each time he was sentenced to psychiatric care. A police compilation presented at one of his trials, cited by the government commission that later examined the case, listed 29 killings in Sweden, Norway and Finland between 1964 and 1993 that he had claimed. Some of those were time-barred, the commission recorded, some were dropped when he stopped cooperating, and some lacked enough detail to investigate.
In 2008 he withdrew every confession. His lawyers then went case by case. Courts granted retrials in all eight, prosecutors dropped every charge, and district courts entered acquittals; the last became final on November 26, 2013. No conviction against him for any killing stands, and every confession he made at Säter has been withdrawn. He was moved to open care in March 2014.
The same clock that had kept some of his claims from ever reaching a courtroom now protected the officials who had built the convictions. In February 2009 the prosecutor general decided not to open a criminal investigation into the prosecutor and the interviewer in the cases, because any offenses would be time-barred. When the last charge was dropped on July 31, 2013, the prosecutor general, Anders Perklev, said it was plainly damaging to public trust that a person had been wrongly convicted of eight murders, and added that any misconduct by officials was time-barred.
Time ran against the claimants as well. Johan Asplund’s parents asked the state for damages and an apology. On April 26, 2017, the Chancellor of Justice rejected the claim, holding that criticism alone did not make the state liable, and that the claim was in any case time-barred. Bergwall himself sought 15 million kronor for his years in detention. On June 25, 2018, the Chancellor of Justice, Anna Skarhed, refused: the claim for the years up to October 19, 2007, was time-barred, and for the later years there was too little to show that the overturned convictions, rather than his assessed mental disorder, had caused his detention.
Partway through the Bergwall retrials, Sweden changed its law. On November 5, 2009, the government put before the Riksdag a bill titled Avskaffande av preskription för vissa allvarliga brott, the abolition of limitation for certain serious crimes. Until then, the bill recorded, the limitation period for murder had been 25 years and for manslaughter 15. The new rules removed the limit for murder and manslaughter, for genocide and gross violations of international law, and for terrorist offenses committed through murder or manslaughter, with attempts included. They did not cover offenders who had been under 21 at the time of the crime. They took effect on July 1, 2010.
The bill was not retroactive in the full sense. It applied to crimes committed before that date only where the possibility of punishment had not already lapsed under the old rules. A murder from 1980 was gone by 2005 and stayed gone. A murder from 1990 was still inside its 25 years in 2010, and so it would never expire.
That line runs straight through the cases Bergwall was once convicted of. Several of the deaths for which he now stands acquitted remain unsolved. SVT reported in 2019 that the Therese Johannessen case was not time-barred and was being investigated as a cold case, and that Gry Storvik’s death was being treated the same way. The killings once charged against a man who did not commit them can still, in law, be charged against someone else.
Russian law draws its line differently. Article 78 of the Criminal Code releases a person from criminal liability once fixed periods have passed since the crime: two years for crimes of minor gravity, six for those of medium gravity, ten for grave crimes and fifteen for especially grave ones. Part 4 of the article adds a rule for crimes punishable by death or life imprisonment: whether the limitation period applies is a question the court decides. If the court declines to release the defendant, the code says, neither death nor life imprisonment may be imposed.
Alexander Pichushkin, a Moscow store worker, was tried in 2007 for killings that stretched back to 1992. Prosecutors sent the case to the Moscow City Court on June 29, 2007, charging him with 49 murders and three attempted murders under Part 2 of Article 105, the murder of people in a helpless state committed with particular cruelty. Before the trial ended the prosecution withdrew one count, the killing of Vladimir Ushakov, which he denied. On October 24, 2007, a jury convicted him of 48 murders and three attempted murders, the first of them the killing of Mikhail Odiychuk in 1992. On October 29 he was sentenced to life in a special-regime colony.
On February 14, 2008, the Supreme Court of Russia refused his request to reduce it to 25 years. Four months later, in June 2008, Vesti reported a detail that had not been part of the first accounts: the Supreme Court had dropped one episode under the statute of limitations, without changing the sentence. Neither report named the episode, and no revised total was published. Most later reports continued to give 48; some gave 49, the number in the original indictment.
So one of the killings of which a Moscow jury convicted Pichushkin no longer stands as a conviction, not because the jury was wrong but because the calendar was. It made no practical difference to a man serving life. As of August 25, 2026, Vesti reported, he was serving his life term at the Polar Owl colony in Kharp, in the Yamalo-Nenets Autonomous Okrug.
Mikhail Popkov made the limitation clock part of his defense in a way few prisoners have. A former police officer in Angarsk, in the Irkutsk Region of Siberia, he left the police in 1998 as a junior lieutenant. He was arrested near Vladivostok on June 23, 2012, after a DNA sample he had given in Angarsk that March was matched to the series under investigation. On January 14, 2015, the Irkutsk Regional Court convicted him of 22 murders of women and of attempted murder, and sentenced him to life.
He was not sent on to a colony. Held in pretrial detention in Irkutsk, he wrote more than 20 confessions to new crimes. On December 10, 2018, the same court convicted him of 56 more murders, 55 of women and one of a fellow police officer in 1999, and gave him a second life sentence, with the loss of his rank. His appeal, registered on December 20, 2018, challenged the loss of rank, Interfax reported, and argued that the statute of limitations had run out for the earliest murders. Before the Supreme Court his defense asked for the limitation period to be applied to murders committed from 1994 to 2003. The court rejected the appeal and left the verdict unchanged, Interfax reported on April 11, 2019.
The confessions kept coming, and so did the arithmetic. On June 4, 2021, the Angarsk City Court convicted him of the murder of two women in 1995 and sentenced him to nine years and eight months, combined with the earlier verdict into a life term. Interfax reported that day that investigators linked him to 81 murders and three attempted murders between 1992 and 2010, and that he had been convicted of 78, the statute of limitations having run out in some cases. Later verdicts followed in 2023 and 2025, each a term of years folded into the life sentence. By the authorities' own running counts the total reached 91 murders, a figure that does not match the sum of the verdict counts.
On December 1, 2025, the Angarsk City Court convicted him of two killings of women in August 2008 and sentenced him to ten years, which under the rules for combining sentences left his punishment at life. His lawyers appealed on January 15, 2026. They argued that the limitation period for the 2008 killings had expired and that the prosecution should be ended. They also cited his age and health. The Irkutsk Regional Court rejected the appeal. It saw no grounds to release him from liability, RBC reported on March 4, 2026, because of the heightened public danger of the crime.
That is Part 4 of Article 78 at work. The 2008 killings were older than the longest period on that list when the case reached court, and the decision whether that mattered belonged to the judges. They decided it did not. After the last verdict took effect he was moved from Irkutsk to a special-regime colony in Mordovia, Altapress reported on April 6, 2026.
In the United States, the limitation question for murder was largely settled long ago, and one of the cases that settled it came out of a New Jersey courtroom in the 1970s.
Rosemary Calandriello was 17, from Atlantic Highlands in Monmouth County, when she went out on an errand on August 25, 1969. Two days later Robert Zarinsky of Linden was arrested in Linden on a complaint of contributing to the delinquency of a minor, later amended to abduction. That charge was dismissed in June 1970 because it had not been presented to a grand jury without unnecessary delay. On February 20, 1975, about five and a half years after the events, a Monmouth County grand jury indicted him for her murder. Her body has never been recovered. The State had no confession to police, and the case rested largely on circumstantial evidence, including statements he made to men held with him in jail. The jury convicted him of first degree murder, and he received the sentence the law then required, life imprisonment.
His main argument on appeal was time. New Jersey law set a five-year limit for most crimes but exempted offenses "punishable with death." The state’s death penalty could no longer be enforced after a 1972 decision, he argued, so murder was no longer punishable with death, and the five-year limit applied. Five and a half years had passed. The Appellate Division rejected the argument on July 20, 1976.
The New Jersey Supreme Court agreed to hear only that one question. It ruled on November 17, 1977, in an opinion by Justice Pashman. "We hold that there is no statute of limitations for murder in New Jersey," the court wrote. It traced the exemption of murder back to the state’s first limitations statute in 1796, said the Legislature had always exempted murder, and added that it had "never recognized any fundamental right to avoid criminal prosecution due solely to passage of time." The conviction stood.
The ruling then reached back into Zarinsky’s own past. In 2001 a Union County jury in Elizabeth tried him for the 1958 killing of Charles Bernoskie, a Rahway police officer, more than four decades after the event. After eight hours of deliberation it acquitted him, and the acquittal is final. Later he was indicted for the 1968 murder of Jane Durrua, a 13-year-old from Keansburg, and pleaded not guilty. He died in the hospice unit of South Woods State Prison in November 2008, awaiting that trial. In 2016 the New Jersey State Police and the Monmouth County Prosecutor’s Office said DNA linked him to the 1965 killing of Mary Agnes Klinsky, 18. He was never charged in that case, and no court has ruled on the attribution.
None of those later prosecutions would have been possible under the rule he had asked for. The case of a man who tried to use the calendar became the case that took the calendar away.
The American rule left an opening, and the Altemio Sanchez case showed how wide it was. Murder had no deadline in New York. Rape did.
Sanchez, a married father of two from Cheektowaga, a suburb east of Buffalo, was arrested in Buffalo on January 15, 2007, by a joint police task force. Police said DNA tied him to a series of sexual assaults on women in and around Buffalo that had gone unsolved for more than 25 years, and to three killings: Linda Yalem in 1990, Majane Mazur of Buffalo in 1992 and Joan Diver of Clarence in 2006. District Attorney Frank Clark said the DNA match was 100 percent.
Within days it was plain that none of the rapes would be tried. New York’s five-year statute of limitations for rape had expired on all of them, including the 1981 case that had first pointed investigators toward him. Clark said prosecutors had long argued that the limit defied common sense. The Legislature had removed it for B-felony sexual assaults in June 2006, seven months before the arrest. The change was not retroactive. It applied to new cases and to cases still inside the five-year window, so it did nothing for the women assaulted in the 1980s and 1990s. Clark said he was surprised how few people knew the law had changed, and when Attorney General Andrew Cuomo was asked about it in Buffalo that week, he said he had not known either.
On May 16, 2007, Sanchez pleaded guilty before State Supreme Court Justice Christopher Burns to three counts of second-degree murder. Prosecutors told reporters that DNA tied him to eight or nine rapes and that they suspected him in about a dozen more between the late 1970s and the mid-1990s. Days before sentencing, his lawyer, Andrew LoTempio, said his client had admitted raping 12 to 15 women since 1979, WBFO reported on August 10, 2007. None of those admissions could lead to a charge.
He was sentenced on August 14, 2007, to 75 years to life, the maximum. "I did these crimes," he told the court. "I should pay for these crimes." He paid for three. The others, admitted through his lawyer and tied to him by laboratory work, were beyond the reach of any court, and so were the survivors' chances of hearing a verdict. His DNA also cleared a Buffalo man who had spent about 22 years in custody for two of the earlier assaults. Sanchez died in state custody on September 22, 2023, at 65; the State Commission of Correction later ruled the manner of death suicide.
The statutes in these cases were written for ordinary crimes and ordinary memory. They assume that evidence fades with the years and that a person who has lived twenty quiet years has some claim on being left alone. Serial cases break those assumptions. Proof surfaces late, from a laboratory or from a prisoner talking to a journalist in a penitentiary, and it arrives for crimes the law had already folded away.
The responses differ by country. Sweden abolished the limit for murder in 2010 but left untouched every case that had already expired. New Jersey announced in 1977 that murder had never had a limit at all. New York closed the gap for the most serious rapes in 2006, months too late for the women whose cases Sanchez had outlasted. Russia lets a judge decide case by case, and in Angarsk the judges have decided against the man who asked. France in 1851 could only let the old deaths speak as character evidence and try the three it still could.
Chile has not finished deciding. On October 26, 2026, the Valparaiso Court of Appeals held that the deaths of Elena Hinojosa and her son had passed beyond the law’s reach in January 2015, more than nine years before Hugo Bustamante gave a journalist their names. The Supreme Court now holds the question. Whatever it rules, the family already knows what he said. What the law can say about it depends on a date.
• June 17, 1803: Hélène Jégado born at Plouhinec, Morbihan.
• 1833 to 1841: deaths in Morbihan households later attributed to Jégado.
• July 1, 1851: Jégado arrested in Rennes.
• December 14, 1851: Jégado convicted of three murders, four attempted murders and 11 thefts; the Morbihan deaths lie beyond the ten-year limit.
• February 26, 1852: Jégado executed at Rennes.
• 1958: Rahway police officer Charles Bernoskie killed.
• August 25, 1969: Rosemary Calandriello’s death, later proved at Robert Zarinsky’s trial.
• February 20, 1975: Zarinsky indicted for murder; convicted later that year.
• July 20, 1976: New Jersey Appellate Division rejects Zarinsky’s limitations argument.
• November 17, 1977: New Jersey Supreme Court holds that there is no statute of limitations for murder in the state.
• 1992: earliest killing in Alexander Pichushkin’s conviction, and in Mikhail Popkov’s series.
• 1994 to 2001: Sture Bergwall (Thomas Quick) convicted of eight murders in six trials.
• June 27, 1996: killings of Elena Hinojosa and Eduardo Paez in Villa Alemana, as held at first instance in 2026.
• January 2005: Hugo Bustamante kills Veronica Vasquez and her son Eugenio; convicted later that year.
• June 2006: New York removes the statute of limitations for B-felony sexual assaults, not retroactively.
• January 15, 2007: Altemio Sanchez arrested in Buffalo; the rapes linked to him are already time-barred.
• May 16, 2007: Sanchez pleads guilty to three counts of second-degree murder.
• October 24, 2007: Pichushkin convicted of 48 murders and three attempted murders.
• February 14, 2008: Supreme Court of Russia upholds Pichushkin’s life sentence; one episode later reported dropped under the statute of limitations.
• November 2008: Zarinsky dies in prison awaiting trial in the Durrua case.
• February 2009: Swedish prosecutor general declines to investigate officials in the Bergwall cases because any offenses would be time-barred.
• July 1, 2010: Sweden abolishes the limitation period for murder for crimes not already time-barred.
• June 23, 2012: Popkov arrested near Vladivostok.
• November 26, 2013: Bergwall’s last acquittal becomes final.
• January 14, 2015: Popkov convicted of 22 murders.
• January 2015: by the Valparaiso Court of Appeals' count, the limitation period for the 1996 Villa Alemana killings runs out.
• December 10, 2018: Popkov convicted of 56 more murders; his appeal raises the statute of limitations.
• April 11, 2019: Supreme Court of Russia rejects Popkov’s appeal.
• June 4, 2021: Interfax reports Popkov convicted of 78 of 81 murders linked to him, limitation a factor in some cases.
• June 6, 2024: CIPER publishes Bustamante’s account naming Eduardo Paez and his mother.
• January 30, 2026: Bustamante convicted at first instance of the 1996 killings.
• March 4, 2026: Irkutsk Regional Court rejects Popkov’s limitations appeal on the 2008 killings.
• October 26, 2026: Valparaiso Court of Appeals' ruling dismissing the 1996 case as time-barred is reported; the family appeals to the Supreme Court.