Pa. Cons. Stat. » 18 Pa. Cons. Stat. (CRIMES AND OFFENSES) / Chapter 39
Pennsylvania Consolidated Statutes

18 Pa. Cons. Stat. § 3902 (2026)

 Consolidation of theft offenses.

✓ current as of May 2026
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§ 3902.  Consolidation of theft offenses.

Conduct denominated theft in this chapter constitutes a single offense. An accusation of theft may be supported by evidence that it was committed in any manner that would be theft under this chapter, notwithstanding the specification of a different manner in the complaint or indictment, subject only to the power of the court to ensure fair trial by granting a continuance or other appropriate relief where the conduct of the defense would be prejudiced by lack of fair notice or by surprise.

Notes of Decisions
Cited in 23 cases (3 in the last 5 years), 1975–2023 · leading case: Alexis Barradas Jacome v. Attorney Gen. United States, 39 F.4th 111 (3d Cir. 2022).
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Alexis Barradas Jacome v. Attorney Gen. United States, 39 F.4th 111 (3d Cir. 2022). · cites it 2× “First, Barradas-Jacome claims his conviction for receipt of stolen property cannot categorically qualify as an aggravated felony because Pennsylvania consolidates all theft offenses under 18 Pa. Cons. Stat. § 3902 , and those theft offenses criminalize more than 8 U.”
Commonwealth v. Hockenbury, 701 A.2d 1334 (Pa. 1997). · cites it 2× “" 18 Pa.C.S. § 3902. Included in the same chapter are statutes governing theft by unlawful taking, theft by failure to make required disposition of funds received, retail theft, and receiving stolen property.”
Commonwealth v. Peduzzi, 488 A.2d 29 (Pa. 1985). · cites it 2× “[3] In view of this determination, Peduzzi should have been discharged.”
Commonwealth v. Morin, 352 A.2d 189 (Pa. Super. Ct. 1975). · cites it 4× “Section 3902 of the Crimes Code, 18 Pa. C.S. § 3902, does not mean that on appeal an appellate court can substitute a different theft offense for the one the defendant was *543 convicted of in the court below.”
Commonwealth v. Robichow, 487 A.2d 1000 (Pa. 1985). · cites it 2× “In reversing, a panel of our court agreed with the hearing court that the evidence was sufficient to prove theft by receiving stolen property.”
Commonwealth v. Stewart, 473 A.2d 161 (Pa. 1984). · cites it 2× “18 Pa.C.S. § 3902. The temporal relationship between the two offenses with which appellant was charged, moreover, is more theoretical than real.”
McCain v. Pennbank, 549 A.2d 1311 (Pa. 1988). “The matter is admitted unless, within thirty days after service of the request, or within such shorter or longer time as the court may allow, the party to whom the request is directed serves upon the party requesting the admission a verified answer or an objection addressed to…”
Commonwealth v. Lawson, 461 A.2d 807 (Pa. 1983). · cites it 2× “I do so, however, with the understanding that we are not in any way restricting or limiting the Legislative direction contained in § 3902 of the Crimes Code, 18 Pa.C.S. § 3902, or the statement of this Court in Commonwealth v.”
Lowry v. State Farm Ins. Companies, 572 A.2d 700 (Pa. 1990). · cites it 2× “18 Pa.C.S. § 3902. In each of the crimes defined under Chapter 39 ("Theft and related offenses") at subchapter B of the Crimes Code, a reading thereof is illuminating as to the symmetry of elements required to constitute a violation.”
Sigafoos v. Commonwealth, Pennsylvania Bd. of Prob. & Parole, 503 A.2d 1076 (Pa. Commw. Ct. 1986). “18 Pa. C. S. §3902. While the original maximum term of ,Sigafoos’ one and one-half to four year sentence, December 16, 1985, is past, he has been convicted of new criminal charges and the Board has revoked his parole and recommitted him to prison as a convicted parole violator…”
United States v. Scarfo, 711 F. Supp. 1315 (E.D. Pa. 1989). “Therefore, these street tax collections are extortions by theft and the knowing receipt of these monies renders the recipient, such as Virgilio, guilty of receiving stolen property under Pennsylvania law.”
Commonwealth v. Lewis, 445 A.2d 798 (Pa. Super. Ct. 1982). “Section 3902 of the Crimes Code, 18 Pa.C.S. § 3902, is very clear. It provides: Conduct denominated theft in this chapter constitutes a single offense.”
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