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Pennsylvania Consolidated Statutes

18 Pa. Cons. Stat. § 906 (2026)

 Multiple convictions of inchoate crimes barred.

✓ current as of May 2026
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§ 906.  Multiple convictions of inchoate crimes barred.

A person may not be convicted of more than one of the inchoate crimes of criminal attempt, criminal solicitation or criminal conspiracy for conduct designed to commit or to culminate in the commission of the same crime.

(Dec. 11, 1986, P.L.1517, No.164, eff. 60 days)

Notes of Decisions
Cited in 95 cases (20 in the last 5 years), 1975–2026 · leading case: Commonwealth, Aplt v. Kingston, S.
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Commonwealth, Aplt v. Kingston, S., 143 A.3d 917 (Pa. 2016). · cites it 12× “The question in this case, raised under a derivative theory of ineffective assistance of counsel, is whether that provision proscribes only convictions for two or more distinct inchoate crimes, or whether it also prohibits convictions for two or more counts of the same inchoate…”
Commonwealth v. Jacobs, 39 A.3d 977 (Pa. 2012). · cites it 7× “We accepted review to determine whether Appellant's sentences for these two inchoate crimes are illegal under 18 Pa.C.S. § 906, which bars multiple "convictions" for inchoate crimes "for conduct designed to .”
Commonwealth v. Kelly, 78 A.3d 1136 (Pa. Super. Ct. 2013). · cites it 5× “Having addressed the issues raised by Appellant, we are compelled to discuss the trial court’s purported vacating of Appellant’s conspiracy sentence in its 1925(a) opinion, pursuant to 18 Pa.”
Commonwealth v. Evans, 494 A.2d 383 (Pa. 1985). · cites it 6× “Appellant next challenges the legality of his sentence on the basis of the statutory bar against conviction of multiple inchoate crimes which is set forth in Section 906 of the Crimes Code, 18 Pa.C.S. § 906. "A person may not be convicted of more than one Section 906 offense…”
Commonwealth v. Crocker, 389 A.2d 601 (Pa. Super. Ct. 1978). · cites it 7× “HOFFMAN, Judge: Appellant contends that (1) 18 Pa.C.S. § 906 1 pre- *65 eludes convictions for both attempted theft 2 and possession of an instrument of crime with intent to employ it criminally 3 when both offenses were designed to culminate in the commission of the same crime,…”
Commonwealth v. Williams, 496 A.2d 31 (Pa. 1985). · cites it 4× “Thus, 18 Pa.C.S. § 906 ("Multiple convictions barred") forbids multiple convictions for "inchoate offenses" designed to commit or culminate in commission of the same crime; and id.”
Commonwealth v. Hale, 85 A.3d 570 (Pa. Super. Ct. 2014). · cites it 2× “2d 1284 (1992), a panel of this Court declined to reverse guilty verdicts on three counts of solicitation to commit involuntary deviate sexual intercourse under 18 Pa.C.S. § 906 8 be *582 cause the court imposed a sentence on only one of those offenses.”
Commonwealth v. Graves, 508 A.2d 1198 (Pa. 1986). · cites it 4× “Section 906 of the Crimes Code, 18 Pa.C.S. § 906, states: “[a] person may not be convicted of more than one offense defined by this chapter for conduct designed to commit or to culminate in the commission of the same crime.”
Commonwealth v. Thompson, 106 A.3d 742 (Pa. Super. Ct. 2014). “The court only sentenced on the attempted burglary count, but the defendant maintained that the guilty verdicts for conspiracy and attempted burglary violated the then-applicable version of 18 Pa.C.S. § 906. The Maguire panel disagreed.”
Commonwealth v. Ford, 461 A.2d 1281 (Pa. 1983). · cites it 2× “pursuant to 18 Pa.C.S. § 906." (Appellant's Brief at 3) Since we find that the evidence presented was sufficient to establish appellant's guilt as to some, but not all, of the offenses charged, we will deal with each offense separately for ease of discussion.”
Commonwealth v. Jordan, 212 A.3d 91 (Pa. Super. Ct. 2019). “Additionally, we note that the parties do not discuss the applicability of 18 Pa.C.S. § 906 ("A person may not be convicted of more than one of the inchoate crimes of criminal attempt, criminal solicitation or criminal conspiracy for conduct designed to commit or to culminate in…”
Com. v. Rosario, K., 248 A.3d 599 (Pa. Super. Ct. 2021). “Did the trial court err by sentencing [Appellant] on charges of criminal attempt-homicide and criminal conspiracy in violation of 18 Pa.C.S. § 906? VI. Did the trial court err in imposing two separate sentences for same-episode conduct constituting a “kidnapping” under 18 Pa.”
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