Marshall was expected to go to court June 11 for two misdemeanor counts of battery, stemming from a March 2008 arrest involving his former girlfriend, Rasheeda Watley.
The outcome of the case could subject Marshall to punishment from the NFL even though it was part of what triggered his summons to commissioner Roger Goodell's office last summer, when Marshall was suspended for the season opener after a series of police-related incidents involving Watley.
"The discipline he received last year [one-game suspension without pay plus an additional fine of one game check] did not
include the resolution of the March '08 incident, which is pending," league spokesman Greg Aiello told The AP.
"The pending case will be subject to review when appropriate. The notification he received from our office [Tuesday] applied only to the March 1 incident of this year," Aiello said.
In that case, Marshall and his new fiance, Michi Leshase Nogami-Campbell, got into a fight in Atlanta on March 1. Charges of disturbing the peace were dropped the next day when Marshall and Nogami-Campbell refused to testify against each other.
Denver coach Josh McDaniels demurred when asked what he thought of the potential punishment still hanging over Marshall's head forrepeated violations of the league's code of conduct.
"It's out of our control. That's something that's a league issue and whatever they come down with or whatever they decide, then we've got to deal with it and we'll do it at that time," McDaniels said. "But there's nothing we can worry about."
Marshall is rehabbing from March 31 hip surgery and hopes to be ready by training camp in late July.
Marshall is due $2.2 million this season in the final year of a four-year contract he signed as a rookie. Although he's had
back-to-back 100-catch seasons and made the Pro Bowl this year, there are questions about what kind of player he'll be coming off hip surgery.
Marshall caught 104 passes for 1,265 yards and six TDs last season. But he dropped 18 on-target passes, something he blamed on the nerve damage in his right arm, which he said he put through a television set while horsing around with his brother a year ago in the offseason.
The Associated Press contributed to this report.