The three-page memo blasted Dixon for failing to show any public contrition after a jury found her guilty in December of embezzling roughly $500 worth of retail gift cards. In January, Dixon also pleaded guilty to one count of perjury.
"It seems Ms. Dixon's unrepentant position is that the people of Baltimore should be willing to tolerate some corruption from their political leaders," wrote State Prosecutor Robert A. Rohrbaugh. "Such defiant arrogance by a political leader is simply unacceptable."
Later he wrote: "While the people of Baltimore are owed a full, complete and truthful explanation from their former mayor, it is probably too much to expect."
Dixon's lead defense attorney, Arnold M. Weiner, declined to comment on the court filing. Dixon did not respond to requests for an interview.
The mayor will have a chance to speak Thursday at a sentencing hearing in Baltimore Circuit Court. Weiner declined to say whether Dixon plans to exercise that right.
Last month, Dixon agreed to a plea deal that will allow her to expunge her criminal record and keep her $83,000 annual city pension in exchange for leaving office. Dixon also has to perform 500 hours of community service and donate $45,000 to charity.
Rohrbaugh wrote that allowing Dixon to keep the pension was "difficult for everyone, including the prosecution team, to swallow."
The deal prohibits Dixon from using any taxpayer funds to pay her legal bills for what Rohrbaugh called her "stable" of seven attorneys. He estimated that her defense costs "might well exceed a million dollars." Privately, some defense attorneys have estimated that the cost could be twice that.
Rohrbaugh's memo also raised issues that were never addressed in the mayor's theft trial, including questions about the source of what prosecutors calculated as $13,800 in unexplained cash that circulated through her checking account in early 2004 when she was dating Baltimore developer Ronald H. Lipscomb.
"Was it just a coincidence that the cash was deposited at the exact moment she needed to pay for her extravagant purchases, including those Jimmy Choo shoes?" Rohrbaugh wrote, noting the designer shoes Dixon bought while she and Lipscomb were on a trip to Chicago. Those gifts were not disclosed on the mayor's city ethics forms.
But the prosecutor wrote that making the plea deal will let the city move on.
"In doing so," Rohrbaugh concluded, "this defendant will finally become yesterday's news."