pre-sentencing standard (Pennsylvania) · Go Syfert
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pre-sentencing standard in Pennsylvania

15 Pennsylvania opinions name it 2 courts 1988–2021 6 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Commonwealth v. Hernandezgreen
pasuperct · 2007 · cited in 6 Pennsylvania opinions naming this issue, 2015–2021
2 sentences

2021Commonwealth v. Hernandez, . . . 917 A.2d 332, 336-37 (Pa. Super. 2007).

2021Commonwealth v. Hernandez, . . . 917 A.2d 332, 336-37 (Pa. Super. 2007).

46
Commonwealth v. Childsgreen
pasuperct · 2013 · cited in 4 Pennsylvania opinions naming this issue, 2015–2021
2 sentences

2021See [Commonwealth v.] Ford, [ 217 A.3d 824 ,] 827 n.6 [(Pa. 2019)] (citing Pa.R.Crim.P. 706) (“[A] pre[-]sentence ability-to-pay hearing is not required when costs alone are imposed.”[)] (emphasis in original)); see also Commonwealth v. Childs, 63 A.3d 323, 326 (Pa. Super. 2013) (“Generally, a defendant is not entitled to a pre-sentencing hearing on his or her ability to pay costs.”).

2021Given the affirmance of Lehman I and the phrasing of § 1403, we must apply the line of precedent holding that challenges to the sentencing court’s authority to impose costs sounds in legality of sentence. - 24 - J-S35012-20 ability-to-pay hearing is not required when costs alone are imposed.” (emphasis in original)); see also Commonwealth v. Childs, 63 A.3d 323, 326 (Pa.Super. 2013) (“Generally, a defendant is not entitled to a pre- sentencing hearing on his or her ability to pay costs.”).

44
Commonwealth v. Muntzgreen
pasuperct · 1993 · cited in 3 Pennsylvania opinions naming this issue, 2015–2020
2 sentences

2020We concluded that, because Muntz did not seek to withdraw his guilty plea prior to his original sentencing, but only before resentencing, his request fell under “the scrutiny of the post-sentencing standard of ‘manifest injustice’ rather than the pre-sentencing standard of ‘fair and just reason.’” Id. at 54 .

2015S76002/14 injustice” rather than the pre-sentencing standard of “fair and just reason.” Id. at 54 (footnote omitted).

13
Buck v. Beardgreen
pa · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015See Buck v. Beard, 879 A.2d 157, 161 (Pa. 2005) (holding that a sentencing hearing provides all the process required before deductions are made from an inmate account); see also Childs, 63 A.3d at 326 (holding that, pursuant to Pa.R.Crim.P. 706, a pre-sentencing hearing regarding the defendant’s ability to pay is only required prior to the entry of an order directing his imprisonment for failure to pay the ordered costs). -7- J-S01004-15 Judgment Entered.

11
Commonwealth v. Iseleygreen
pasuperct · 1992 · cited in 1 Pennsylvania opinions naming this issue, 1993–1993
2 sentences

1993“The rule in Forbes is made, perhaps oversolicitously, in favor of justice, to protect against the possibility that an innocent defendant will erroneously plead guilty.” Commonwealth v. Iseley, 419 Pa.Super. 364, 375 , 615 A.2d 408, 413 (1992).

1993“The rule in Forbes is made, perhaps oversolicitously, in favor of justice, to protect against the possibility that an innocent defendant will erroneously plead guilty.” Commonwealth v. Iseley, 419 Pa.Super. 364, 375 , 615 A.2d 408, 413 (1992).

11
Commonwealth v. Doriangreen
pasuperct · 1983 · cited in 1 Pennsylvania opinions naming this issue, 1988–1988
2 sentences

1988See Commonwealth v. Anthony, 504 Pa. 551 , 475 A.2d 1303 (1984); Commonwealth v. Dorian, 314 Pa.Super. 244, 248 , 460 A.2d 1121, 1123 (1983), *173 aff'd 503 Pa. 116 , 468 A.2d 1091 (1983).

1988See Commonwealth v. Anthony, 504 Pa. 551 , 475 A.2d 1303 (1984); Commonwealth v. Dorian, 314 Pa.Super. 244, 248 , 460 A.2d 1121, 1123 (1983), *173 aff'd 503 Pa. 116 , 468 A.2d 1091 (1983).

11
Commonwealth v. Anthonygreen
pa · 1984 · cited in 1 Pennsylvania opinions naming this issue, 1988–1988
2 sentences

1988See Commonwealth v. Anthony, 504 Pa. 551 , 475 A.2d 1303 (1984); Commonwealth v. Dorian, 314 Pa.Super. 244, 248 , 460 A.2d 1121, 1123 (1983), *173 aff'd 503 Pa. 116 , 468 A.2d 1091 (1983).

1988See Commonwealth v. Anthony, 504 Pa. 551 , 475 A.2d 1303 (1984); Commonwealth v. Dorian, 314 Pa.Super. 244, 248 , 460 A.2d 1121, 1123 (1983), *173 aff'd 503 Pa. 116 , 468 A.2d 1091 (1983).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Commonwealth v. Middleton green
pa · 1984
2 sentences

1993In addition, we note that, in Commonwealth v. Middleton, 504 Pa. 352 , 473 A.2d 1358 (1984), the Supreme Court of Pennsylvania held that the pre-sentencing standard applied to appellee’s motion to withdraw his guilty plea because a sentence hearing had not convened and because sentence had not been imposed for any of the crimes charged.

1993In addition, we note that, in Commonwealth v. Middleton, 504 Pa. 352 , 473 A.2d 1358 (1984), the Supreme Court of Pennsylvania held that the pre-sentencing standard applied to appellee’s motion to withdraw his guilty plea because a sentence hearing had not convened and because sentence had not been imposed for any of the crimes charged.

11993–1993
Commonwealth v. Forbes green
pa · 1973
2 sentences

1993Therefore, appellant’s request falls under the scrutiny of post-sentencing standard of “manifest injustice” rather than the pre-sentencing standard of “fair and just reason.” 5 *105 In Commonwealth v. Forbes, 450 Pa. 185 , 299 A.2d 268 (1973), the Supreme Court of Pennsylvania held that a mere claim of innocence constitutes a “fair and just reason” for the pre-sentence withdrawal of a guilty plea unless there is substantial prejudice to the Commonwealth.

1993Therefore, appellant’s request falls under the scrutiny of post-sentencing standard of “manifest injustice” rather than the pre-sentencing standard of “fair and just reason.” 5 *105 In Commonwealth v. Forbes, 450 Pa. 185 , 299 A.2d 268 (1973), the Supreme Court of Pennsylvania held that a mere claim of innocence constitutes a “fair and just reason” for the pre-sentence withdrawal of a guilty plea unless there is substantial prejudice to the Commonwealth.

11993–1993
Commonwealth v. Dorian green
pa · 1983
2 sentences

1988See Commonwealth v. Anthony, 504 Pa. 551 , 475 A.2d 1303 (1984); Commonwealth v. Dorian, 314 Pa.Super. 244, 248 , 460 A.2d 1121, 1123 (1983), *173 aff'd 503 Pa. 116 , 468 A.2d 1091 (1983).

1988See Commonwealth v. Anthony, 504 Pa. 551 , 475 A.2d 1303 (1984); Commonwealth v. Dorian, 314 Pa.Super. 244, 248 , 460 A.2d 1121, 1123 (1983), *173 aff'd 503 Pa. 116 , 468 A.2d 1091 (1983).

11988–1988

Where else courts name it

TX 23 (2001–2018) PA 15 (1988–2021) GA 7 (1980–2017) IL 6 (1968–1985) AZ 4 (1978–2005) WI 4 (1997–2019) VA 2 (2012–2024)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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