SORNA registration beyond maximum limit of incarceration is legal

Comm. v. Strafford, 2018 PA Super 223 (Aug. 6, 2018) Out of Delaware County. The Superior Court addressed an issue of first impression: whether a lifetime registration requirement under SORNA, which exceeds the statutory maximums of convicted offenses, renders the sentence illegal.  The Superior Court held that such a lifetime registration does not render the sentence illegal. The Superior Court … Read More

The Rule of Completeness: An assist from the bench

Comm. v. Thomas, 2018 PA Super 221 (Aug. 3, 2018) Out of Philadelphia County. Thomas was convicted of first-degree murder.  Three issues were raised in this appeal, but only one was of particular note that caught my attention.  It dealt with what is referred to as the “Rule of Completeness,” which is an evidentiary concept tied up in Rule 106 … Read More

Tipsters more reliable when they provide self-incriminating details

Comm. v. Butler, 2018 PA Super 219 (Aug. 1, 2018) Out of Bucks County.  Butler was convicted of drug-related offenses, namely possession with intent to deliver (PWID).  He raised a single issue on appeal: whether the police had reasonable suspicion to conduct an investigative detention?  The Superior Court, like the trial court, held that there was reasonable suspicion. Essentially, the … Read More