summary offense violation in Pennsylvania

2017See, e.g., Williamson, 129 A.3d at 602 (stating that the licensee’s “subjective misunderstanding or confusion related to the straightforward appeal language in the Bureau’s notice of suspension cannot, by itself justify extension of the statutorily mandated 30-day appeal period”); Baum, 949 A.2d at 349-50 (motorist barred from filing nunc pro tunc appeal of suspension of operating privileges where she appealed an underlying summary offense violation and filed a request for a stay of the suspension but mistakenly did not file a timely appeal of the notice of suspension); Kovalesky v. Department

2017See, e.g., Williamson, 129 A.3d at 602 (stating that the licensee’s “subjective misunderstanding or confusion related to the straightforward appeal language in the Bureau’s notice of suspension cannot, by itself justify extension of the statutorily mandated 30-day appeal period”); Baum, 949 A.2d at 349-50 (motorist barred from filing nunc pro tunc appeal of suspension of operating privileges where she appealed an underlying summary offense violation and filed a request for a stay of the suspension but mistakenly did not file a timely appeal of the notice of suspension); Kovalesky v. Department

2017See, e.g., Williamson, 129 A.3d at 602 (stating that the licensee’s “subjective misunderstanding or confusion related to the straightforward appeal language in the Bureau’s notice of suspension cannot, by itself justify extension of the statutorily mandated 30-day appeal period”); Baum, 949 A.2d at 349-50 (motorist barred from filing nunc pro tunc appeal of suspension of operating privileges where she appealed an underlying summary offense violation and filed a request for a stay of the suspension but mistakenly did not file a timely appeal of the notice of suspension); Kovalesky v. Department

2017See, e.g., Williamson, 129 A.3d at 602 (stating that the licensee’s “subjective misunderstanding or confusion related to the straightforward appeal language in the Bureau’s notice of suspension cannot, by itself justify extension of the statutorily mandated 30-day appeal period”); Baum, 949 A.2d at 349-50 (motorist barred from filing nunc pro tunc appeal of suspension of operating privileges where she appealed an underlying summary offense violation and filed a request for a stay of the suspension but mistakenly did not file a timely appeal of the notice of suspension); Kovalesky v. Department

2002See Commonwealth v. Geyer, 546 Pa. 586 , 687 A.2d 815, 818 (1996). ¶ 14 In the case sub judice, the compulsory joinder rule does not apply.

2002We concluded in Taylor that “since the harassment charge, as a summary offense, was in the jurisdiction of the district justice, conviction or a plea of guilty to that charge in a summary proceeding did not bar the subsequent trial of the [misdemeanor] weapons offense.” Geyer, 687 A.2d at 817 . ¶ ? 13 Review of these cases makes apparent that a conviction on a summary offense does not bar the subsequent trial of a misdemeanor or felony charge.

1980See also Screws v. United States, 325 U.S. 91, 101 , 65 S.Ct. 1031, 1035 , 89 L.Ed. 1495 (1945) (plurality opinion) (“[t]he requirement of a specific intent to do a prohibited act may avoid those consequences to the accused which may otherwise render a vague or indefinite statute invalid”).

1980See also Screws v. United States, 325 U.S. 91, 101 , 65 S.Ct. 1031, 1035 , 89 L.Ed. 1495 (1945) (plurality opinion) (“[t]he requirement of a specific intent to do a prohibited act may avoid those consequences to the accused which may otherwise render a vague or indefinite statute invalid”).