mistake of fact defense (Pennsylvania) · Go Syfert
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mistake of fact defense in Pennsylvania

9 Pennsylvania opinions name it 1 courts 2000–2025 5 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. Fischergreen
pasuperct · 1998 · cited in 2 Pennsylvania opinions naming this issue, 2000–2025
2 sentences

2025See Commonwealth v. Williams, 439 A.2d 765, 769 (Pa. Super. 1982); Commonwealth v. Fischer, 721 A.2d 1111, 1118 (Pa. Super. 1998) (applying Williams).

2000See Fischer, 721 A.2d at 1113 .

22
Commonwealth v. Namackgreen
pasuperct · 1995 · cited in 2 Pennsylvania opinions naming this issue, 2001–2024
2 sentences

2001Commonwealth v. Namack, 444 Pa.Super. 9 , 663 A.2d 191, 194-195 (1995) (footnotes omitted). ¶ 16 In explaining its reasoning for denying Appellant’s requested instruction, the trial court relies on Cottam for the proposition: “The Superior Court has specifically held that the failure to give a mistake of fact instruction does not constitute error.” Trial Court Opinion, 7/3/00, at 5 (emphasis supplied).

2001Commonwealth v. Namack, 444 Pa.Super. 9 , 663 A.2d 191, 194-195 (1995) (footnotes omitted). ¶ 16 In explaining its reasoning for denying Appellant’s requested instruction, the trial court relies on Cottam for the proposition: “The Superior Court has specifically held that the failure to give a mistake of fact instruction does not constitute error.” Trial Court Opinion, 7/3/00, at 5 (emphasis supplied).

12
Commonwealth v. Williamsgreen
pasuperct · 1982 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025See Commonwealth v. Williams, 439 A.2d 765, 769 (Pa. Super. 1982); Commonwealth v. Fischer, 721 A.2d 1111, 1118 (Pa. Super. 1998) (applying Williams).

11
Commonwealth v. Whitegreen
pa · 1985 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024See Commonwealth v. White, 492 A.2d 32, 35-36 (Pa. Super. 1985) (“An affirmative defense is one where the defendant admits his commission of the act charged, but seeks to justify or excuse.”).

11
Commonwealth v. Wannergreen
pasuperct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024See Commonwealth v. Wanner, 158 A.3d 714, 717 (Pa. Super. 2017) (holding that Wanner waived her argument alleging that there was an affirmative defense to defiant trespass that was applicable to her case, where she failed to raise that defense in the trial court). ____________________________________________ 6 Had Appellant raised this mistake of fact defense theory at trial, he essentially would have admitted that his commission of the sexual acts against L.L. had occurred.

11
Commonwealth v. Bollingergreen
pasuperct · 1962 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016In Commonwealth v. Scott, 73 A.3d 599 (Pa.Super. 2013), we described the mistake of fact defense as follows: It is well established that a bona fide, reasonable mistake of fact may, under certain circumstances, negate the element of criminal intent. 18 Pa.C.S.A. § 304 (providing, inter alia, that ignorance or mistake as to a matter of fact, for which there is a reasonable explanation or excuse, is a defense if “the ignorance or mistake negatives the intent, knowledge, recklessness, or negligence required to establish a material element of the offense”); Commonwealth v. Compel, 236 Pa.Super. 40

2016In Commonwealth v. Scott, 73 A.3d 599 (Pa.Super. 2013), we described the mistake of fact defense as follows: It is well established that a bona fide, reasonable mistake of fact may, under certain circumstances, negate the element of criminal intent. 18 Pa.C.S.A. § 304 (providing, inter alia, that ignorance or mistake as to a matter of fact, for which there is a reasonable explanation or excuse, is a defense if “the ignorance or mistake negatives the intent, knowledge, recklessness, or negligence required to establish a material element of the offense”); Commonwealth v. Compel, 236 Pa.Super. 40

11
Commonwealth v. Lefevergreen
pasuperct · 1942 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016“It is not necessary that the facts be as the actor believed them to be; it is only necessary that he have ‘a bona fide and reasonable belief in the existence of facts which, if they did exist, would render an act innocent.’ Commonwealth v. Lefever, 151 Pa.Super. 351 , 30 A.2d 364, 365 (1943).

2016“It is not necessary that the facts be as the actor believed them to be; it is only necessary that he have ‘a bona fide and reasonable belief in the existence of facts which, if they did exist, would render an act innocent.’ Commonwealth v. Lefever, 151 Pa.Super. 351 , 30 A.2d 364, 365 (1943).

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 (4)

CaseCitedYears
Commonwealth v. Scott green
pasuperct · 2013
2 sentences

2019This Court has explained the mistake of fact defense as follows: It is well established that a bona fide, reasonable mistake of fact may, under certain circumstances, negate the element of criminal intent. 18 Pa.C.S.A. § 304 (providing, inter alia , that ignorance or mistake as to a matter of fact, for which there is a reasonable explanation or excuse, is a defense if "the ignorance or mistake negatives the intent, knowledge, recklessness, or negligence required to establish a material element of the offense")[.] It is not necessary that the facts be as the actor believed them to be; it is onl

2016In Commonwealth v. Scott, 73 A.3d 599 (Pa.Super. 2013), we described the mistake of fact defense as follows: It is well established that a bona fide, reasonable mistake of fact may, under certain circumstances, negate the element of criminal intent. 18 Pa.C.S.A. § 304 (providing, inter alia, that ignorance or mistake as to a matter of fact, for which there is a reasonable explanation or excuse, is a defense if “the ignorance or mistake negatives the intent, knowledge, recklessness, or negligence required to establish a material element of the offense”); Commonwealth v. Compel, 236 Pa.Super. 40

32016–2024
North Carolina v. Alford green
scotus · 1970
2 sentences

2024Based on that information, [Leese] decided to enter an Alford[1] plea [to strangulation]. ____________________________________________ 1 North Carolina v. Alford, 400 U.S. 25 , 91 S.Ct. 160 , 27 L.Ed.2d 162 (1970). -2- J-S39028-23 PCRA Court Opinion in Support of Order Pursuant to Pa.R.A.P. 1925(a) (“PCRA Ct. Rule 1925(a) Op.”), filed 3/20/23, at 1-4 (citations and footnote omitted).

2024Based on that information, [Leese] decided to enter an Alford[1] plea [to strangulation]. ____________________________________________ 1 North Carolina v. Alford, 400 U.S. 25 , 91 S.Ct. 160 , 27 L.Ed.2d 162 (1970). -2- J-S39028-23 PCRA Court Opinion in Support of Order Pursuant to Pa.R.A.P. 1925(a) (“PCRA Ct. Rule 1925(a) Op.”), filed 3/20/23, at 1-4 (citations and footnote omitted).

12024–2024
Commonwealth v. Lesko green
pa · 2011
1 sentence

2023In this instance, the court determined that Appellant failed to show that he suffered actual prejudice, i.e., “that but for the [counsel’s failure to request the mistake of fact instruction], the outcome of the proceedings would have been -5- J-A08008-23 different.” PCRA Court Amended Rule 1925(a) Opinion, 9/14/22, at 6 (quoting Commonwealth v. Lesko, 15 A.3d 345 (Pa. Super. 2011)).

12023–2023
Commonwealth v. Compel green
pasuperct · 1975
2 sentences

2016In Commonwealth v. Scott, 73 A.3d 599 (Pa.Super. 2013), we described the mistake of fact defense as follows: It is well established that a bona fide, reasonable mistake of fact may, under certain circumstances, negate the element of criminal intent. 18 Pa.C.S.A. § 304 (providing, inter alia, that ignorance or mistake as to a matter of fact, for which there is a reasonable explanation or excuse, is a defense if “the ignorance or mistake negatives the intent, knowledge, recklessness, or negligence required to establish a material element of the offense”); Commonwealth v. Compel, 236 Pa.Super. 40

2016In Commonwealth v. Scott, 73 A.3d 599 (Pa.Super. 2013), we described the mistake of fact defense as follows: It is well established that a bona fide, reasonable mistake of fact may, under certain circumstances, negate the element of criminal intent. 18 Pa.C.S.A. § 304 (providing, inter alia, that ignorance or mistake as to a matter of fact, for which there is a reasonable explanation or excuse, is a defense if “the ignorance or mistake negatives the intent, knowledge, recklessness, or negligence required to establish a material element of the offense”); Commonwealth v. Compel, 236 Pa.Super. 40

12016–2016

Where else courts name it

TX 186 (1983–2026) CA 138 (1961–2026) NM 29 (1978–2026) IN 27 (1985–2020) NY 19 (1975–2020) GA 17 (1975–2026) IL 14 (1991–2025) HI 14 (2002–2026) MA 11 (1988–2023) MI 9 (2000–2026) PA 9 (2000–2025) UT 7 (2009–2026) NJ 6 (1998–2021) CO 6 (1992–2016) ID 5 (1990–2022) NC 5 (1997–2020) SD 5 (1984–2024) OH 4 (2004–2019) KS 4 (2010–2023) MD 4 (2002–2025) MO 4 (1958–2013) TN 3 (1995–2015) KY 3 (1994–2021) AZ 2 (2017–2018) ND 2 (1996–2002) WI 2 (1980–1987) IA 2 (1987–2015) NV 2 (2020–2026) DC 2 (1992–2014) RI 2 (1998–2000) WA 2 (1997–1997)

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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