Third Circuit Court of Appeals: Unnecessary 23-minute Extension of Traffic Stop Requires Suppression of Gun and Marijuana 

 Zak Goldstein - Criminal Lawyer

Zak Goldstein - Criminal Lawyer

The United States Court of Appeals for the Third Circuit has decided the case of United States v. Clark, holding that police violated Clark’s rights by questioning him and the driver of the car he was in for 23 minutes about subjects unrelated to the initial purpose of a traffic stop. The Third Circuit held that the trial court properly granted Clark’s motion to suppress a gun and marijuana found in the car because police impermissibly extended the stop for longer than was necessary to investigate the motor vehicle code violations that led to the stop. 

The Facts of Clark

Clark is an excellent example of how police body camera footage dramatically changes the analysis of routine police searches and seizures. In Clark, police in New Jersey stopped a minivan because the driver was using his cell phone while driving, did not have his headlights on, and had an obstructed view. The police asked to see the paperwork for the vehicle. The driver handed over his license and insurance card, but he could not find the van’s registration. He said the van belonged to his mother, and he offered to call his mother and ask her if she knew where to find the registration. The officer told the driver that the stop was for the three traffic violations and asked whether his license was suspended. The driver said it was not. The officer then asked if the van belonged to the driver’s mother, and the driver confirmed that it did. 

After speaking with the driver, the officer returned to his police car to run the paperwork. He confirmed that the driver’s license was valid, that the driver had a criminal record for drug charges, there were no outstanding arrest warrants for the driver, and the car was registered to a woman with the same last name and address as the driver. The officer then went back to the van and asked the driver about his criminal record. He asked whether the driver had been arrested, for what he had been arrested, and when was the last time he had been arrested. The driver confirmed he had been arrested for drug charges, most recently in 2006. The officer continued questioning the driver as to such things as where he was coming from, whether he and any warrants, and again how many times he had been arrested. 

After questioning the driver for a few minutes, mostly about his criminal record, the officer asked the driver to step out of the vehicle. The driver did so, and the officer then began asking him about Clark, the passenger. After asking a few questions about Clark, the officer walked over to the passenger’s side of the van and asked similar questions of Clark. The officer then returned to the driver and accused him of lying. He then said he smelled marijuana coming from the passenger’s side and asked Clark to get out of the car. Clark complied. The officers told him to turn around for a pat-down, and Clark then told the officers that he had a gun. The officers searched Clark and recovered a gun and a small amount of marijuana. 

Body camera footage showed that police had questioned the two men for about 23 minutes. Had the footage not been recorded, officers likely would have been able to describe the questioning as a “brief encounter,” and Clark would have had much more difficulty establishing what happened that led to the search.

The Motion to Suppress 

After police arrested Clark, the United States Attorney’s Office adopted the case. A federal grand jury indicted Clark for possession of a weapon as a convicted felon in violation of 18 U.S.C. Sec. 922(g)(1). He filed a motion to suppress the gun and the marijuana, arguing that police had impermissibly prolonged the stop beyond its original purpose without the necessary reasonable suspicion or probable cause. The District Court granted the motion to suppress, finding that police had no real basis for extensively questioning the driver about his criminal history and that the officer had no reasonable suspicion to investigate other criminal matters beyond the traffic violations. 

The Federal Appeal 

After the District Court granted the motion to suppress, the United States appealed to the Third Circuit. The Third Circuit affirmed the trial court’s decision on appeal. The Court noted that even when a stop may be lawful at its inception, as the parties agreed in this case, a stop may become illegal as it progresses. In Rodriguez v. United States, the United States Supreme Court recently held that an initially-valid traffic stop may become unlawful when it lasts longer than is necessary for police to complete the mission of the stop. The authority for the seizure ends when tasks tied to the mission are or reasonably should have been completed. In order to prolong a stop beyond that point, a police officer must have acquired additional reasonable suspicion or probable cause during the investigation to justify additional investigation and a lengthening of the stop. 

When police pull a suspect over for a traffic stop, the mission of the stop is to address the traffic violation that warranted the stop and address related safety concerns. This could include deciding whether to issue a ticket, checking the driver’s license and for any outstanding warrants against the driver, and inspecting the vehicle’s registration and insurance. These tasks are all part of ensuring roadway safety. Police may also take steps that are reasonably related to officer safety. However, not all investigation during a traffic stop qualifies as part of the traffic stop’s mission. For example, extensive questioning of the occupants of a vehicle, as occurred here, requires independent reasonable suspicion beyond the observation of a motor vehicle code violation. 

Here, the extensive questioning of the driver regarding his criminal record and where he was coming from had nothing to do with the purpose of the stop. The questions were entirely unrelated to whether he had a driver’s license, insurance, and registration, and they had nothing to do with whether he was lawfully in possession of the car. The driver was cooperative with the officers, he provided proof of insurance and a valid driver’s license, he did not have any outstanding arrest warrants, and the police were able to confirm that the car belonged to the driver’s mother. Accordingly, the police had no basis for believing that the driver should not have been driving the car. Once police confirmed that all of the paperwork for the car was valid, they were required to either issue a ticket or let the car go. They had no authority to then turn to Clark, the passenger, and question him. By doing so, they unconstitutionally extended the length of the stop. Therefore, the District Court properly granted the motion to suppress the gun and the marijuana. This is a great case for individual privacy rights as the Third Circuit has now held that even a relatively short 23-minute stop can violate a defendant’s rights to be free from unreasonable search and seizures.

Facing criminal charges? We can help.

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If you are facing criminal charges or are under investigation by the police, we can help. We have successfully defended thousands of clients against criminal charges in courts throughout Pennsylvania and New Jersey. We have successfully obtained full acquittals in cases involving charges such as Conspiracy, Aggravated Assault, and Attempted Murder. Our award-winning Philadelphia criminal defense lawyers offer a free criminal defense strategy session to any potential client. Call 267-225-2545 to speak with an experienced and understanding defense attorney today. 

PA Superior Court: Commonwealth May Introduce Expert Testimony on Dynamics of Sexual Violence and Victim Responses to Sexual Violence

 Zak T. Goldstein, Esq. - Philadelphia Criminal Lawyer

Zak T. Goldstein, Esq. - Philadelphia Criminal Lawyer

The Pennsylvania Superior Court has decided the case of Commonwealth v. Cramer, affirming the defendant’s convictions for sexual assault and indecent assault. The Superior Court not only held that there was sufficient evidence to convict Appellant, but that the trial court did not abuse its discretion when it allowed the Commonwealth to introduce expert testimony about the dynamics of sexual violence, victim responses to sexual violence, and the impact of sexual violence on victims during and after being assaulted. The Superior Court also affirmed the trial court’s denial of his motion to introduce DNA evidence that showed the complainant had sperm from two other males on her underwear.

Commonwealth v. Cramer

The complainant testified at trial as follows: The complainant met the defendant at a bar in Centre County, Pennsylvania. After meeting at the bar, the complainant and the defendant went to the defendant’s apartment along with the complainant’s roommate. While the complainant was in the bathroom, the defendant entered the bathroom and took of his pants. He then began to penetrate the complainant from behind.

The complainant told the defendant that “he didn’t want to do that.” The defendant did not stop until the complainant “turned around and told him that she didn’t want to do this again and that [she] wasn’t on the pill.” The defendant then asked complainant to engage in oral sex, and the complainant agreed to do so. However, “[s]he stopped giving him oral sex and told him ‘you don’t want this. I don’t want this. This is going to end badly for both of us.’” The complainant’s roommate testified at trial that she heard the complainant say to Appellant “no stop, you don’t want to do this.”

The complainant left the bathroom and eventually left the apartment with her roommate. When they left the apartment, the complainant met a man in the hallway. He testified at trial that the complainant “appeared rattled” and that he inquired if she was okay. The three then went into the man’s apartment so that the complainant’s roommate could use the bathroom. While she was in the bathroom, the complainant told the man and his girlfriend what had happened in the defendant’s apartment. After the roommate was done using the restroom, the two left. They then caught the bus, and this is when the complainant told the roommate about what happened.

Police arrested the defendant, and prosecutors filed charges of Sexual Assault, Indecent Assault, Rape by forcible Compulsion, and Involuntary Deviate Sexual Intercourse by Forcible Compulsion. At trial, the Commonwealth called an expert who testified about how “the manner in which a victim’s response to sexual violence may be counterintuitive.” The defendant attempted to introduce DNA evidence relating to the complainant’s prior sexual contact. Specifically, the defendant attempted to show that there were three contributors of sperm on her underwear. The trial court, however, precluded this testimony based on Pennsylvania’s Rape Shield Law despite the fact that the complainant told hospital staff that she had not slept with anyone two weeks prior to this incident. The defendant testified at trial that this was a consensual sexual encounter. Nonetheless, the jury found him guilty of Sexual Assault and Indecent Assault. The defendant appealed his conviction to the Superior Court.

What is the Rape Shield Law?

On appeal, the defendant argued that he should have been allowed to introduce the DNA evidence that showed the complainant had sperm on her underwear from two other males. Pennsylvania’s Rape Shield Law, 18 P.S.A. § 3104. governs the admissibility of evidence of a victim’s sexual conduct. Generally, it prohibits the introduction of the complainant’s prior sexual history. Its purpose is to prevent a trial from shifting its focus from the culpability of the accused toward the virtue and chastity of the victim. It is designed to prevent a defendant from simply attacking a complainant on the basis of his or her alleged promiscuity as whether or not any given complainant has had sex with other people standing on its own is not a defense to a rape charge. Courts have been mostly consistent in holding that the introduction of evidence relating to a complainant’s prior sexual history is not relevant when the issue in a case is whether consent existed.

At the same time, defendants have a right to cross-examine their accusers under the Pennsylvania and United States Constitutions. Therefore, appellate courts have recognized that the Rape Shield Law must yield to a defendant’s right to cross-examine on relevant topics. Consequently, Pennsylvania courts have created a balancing test that considers whether the proposed evidence is relevant to attack credibility, whether the probative value outweighs the prejudicial impact and whether there are alternative means to challenge credibility. If a defendant seeks to introduce evidence, he or she must first file a written motion with the court and include an offer of proof as to what the evidence is and why the evidence should be admitted. This is known as piercing the Rape Shield. If the court is satisfied with these reasons, then the court will order an in-camera hearing and make findings on the record as to the relevance and the admissibility of the proposed evidence. It is worth noting that on appeal, an abuse of discretion standard applies and thus it can be very difficult to prevail on appeal on the basis that the trial court improperly prohibited the introduction of this type of evidence.

Expert Testimony in Rape Cases

A Pennsylvania law, 42 Pa.C.S.A. § 5920, allows the Commonwealth to introduce expert testimony in sexual assault and many child abuse cases. An expert may testify about “the dynamics of sexual violence, victim responses to sexual violence, and the impact of sexual violence on victims during and after being assaulted.” Notably, the expert cannot testify as to the credibility of the witness. This is significant because courts have overturned convictions when the expert does so.

However, before the court will permit an expert to testify, the Commonwealth may have to show that the witness is in fact an expert. Further, where the Commonwealth seeks to introduce a “novel” form of science, then this science must comply with the Frye standard. The Frye standard requires that the methodology underlying the novel scientific evidence must have general acceptance in the relevant scientific community. The trial court is not required to conduct a Frye hearing any time a party seeks to introduce scientific evidence. Instead, it is only required when the trial court has articulable grounds to believe that an expert witness has not applied accepted scientific methodology in a conventional fashion in reaching his or her conclusions. The opposing party must demonstrate that the expert’s testimony is based on novel scientific evidence, i.e. that there is a legitimate dispute regarding the reliability of the expert’s conclusions.

The Superior Court’s Decision

The Pennsylvania Superior Court affirmed the convictions. The Superior Court found that the trial court did not abuse its discretion when it denied the introduction of the DNA evidence. This is notable because the the defendant could not even use this to impeach the complainant’s credibility. As stated above, the complainant told hospital staff that she had not slept with anyone prior to this incident. Despite the DNA evidence contradicting this statement, the Superior Court still denied the appeal. The Superior Court reasoned that this was not relevant given the Appellant’s argument that this was a consensual sexual encounter. Thus, the only issue was whether the complainant had consented. The fact that she had likely slept with other men did not show whether she had consented or not.

The Superior Court also held that a Frye hearing was not necessary to determine the admissibility of the Commonwealth’s expert testimony. The Superior Court stated that the defense failed to make an initial showing that the Commonwealth’s expert testimony was based on novel scientific evidence. In his Motion in Limine, the defendant argued “the testimony of [Commonwealth Expert] is likely to contain opinions based on the human behavioral sciences of psychology, human development, and science.” Therefore, he did not directly assert that the Commonwealth’s expert’s testimony was based on novel science. Additionally, the Superior Court gave great weight to the expert’s firsthand experience with victims and her own research. Consequently, this appeal was denied, as well. The Court’s reasoning in this regard highlights the importance of making an adequate record when challenging the admissibility of evidence in the trial court. The defendant here offered no evidence that anything about the expert’s testimony was novel; therefore, the court did not have to hold a hearing.

Facing Criminal Charges? We Can Help.

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If you are facing criminal charges or are under investigation by the police, we can help. We have successfully defended thousands of clients against criminal charges in courts throughout Pennsylvania and New Jersey. We have successfully obtained full acquittals in cases involving charges such as Conspiracy, Aggravated Assault, and Attempted Murder. Our award-winning Philadelphia criminal defense lawyers offer a free criminal defense strategy session to any potential client. Call 267-225-2545 to speak with an experienced and understanding defense attorney today. 

 

SORNA Update: PA Superior Court Finds Trial Court Must Reduce Megan’s Law Tier of Registrants Who Had Tiers Retroactively Increased

 Criminal Defense Lawyer Zak Goldstein

Criminal Defense Lawyer Zak Goldstein

The Pennsylvania Superior Court has issued an incredibly important decision for Megan’s Law registrants who found their registration requirements and terms increased by Pennsylvania’s SORNA law. In Commonwealth v. Fernandez, the Court held that trial courts have the jurisdiction to and should reduce Megan’s Law registrants’ registration tiers to the tier that was in effect at the time of the plea. This means that if you initially pleaded guilty to or were found guilty of a Tier I offense for a registration period of ten years and later learned that you would have to register as a Tier III offender for life, you may be able to obtain relief by filing a Petition in the Court of Common Pleas which heard your case. This decision is a no brainer – obviously, the Pennsylvania State Police should not be able to retroactively increase the punishment associated with a conviction. However, until this decision, it was unclear how someone affected by the Supreme Court’s decision in Muniz which found that SORNA could not be applied retroactively could obtain relief or if Muniz even applied retroactively.   

Fernandez is the decision of an en banc panel of the Superior Court, meaning it is binding on all other panels unless reversed by the Pennsylvania Supreme Court. In Fernandez, nineteen Megan’s Law registrants filed identical Petitions to Enforce the Plea Agreement or for a Writ of Habeas Corpus in the Court of Common Pleas of Philadelphia. Each of the defendants had pleaded guilty to charges involving sexual offenses prior to the enactment of Pennsylvania SORNA’s statute on December 20, 2012. Under the previous version of Megan’s Law, two of the defendants pleaded guilty to crimes which did not require sex offender registration at all, and the remaining defendants had to register as Tier I offenders for ten years.

These cases were all unrelated, but there were similarities in terms of the plea bargains. In exchange for the guilty pleas, the Commonwealth withdrew various other charges which would have triggered lengthier periods of Megan’s Law Registration. At sentencing, each defendant was informed of whether they would have to register, and if so, for how long. All nineteen defendants subsequently violated their probation and were sentenced either to new periods of probation or incarceration.

When they were re-sentenced, the defendants were told that the new SORNA law increased their registration requirements – meaning some were now required to register for 15 years, some for 25 years, and some for life. SORNA drastically increased the punishments and Megan’s Law consequences for many sex offenses, converting crimes that did not require registration such as Indecent Assault (M2) into Megan’s Law crimes and increasing the term of registration for many offenders. It even required registration for some crimes which did not involve sex acts. 

Because each of these defendants had pleaded guilty in Philadelphia, they filed the petitions in the Philadelphia Court of Common Pleas. Each defendant challenged the retroactivity of SORNA to their cases and argued that it violated the plea deals that each had made with the Commonwealth. The trial court denied the petitions, finding that the defendants were not entitled to specific performance of the negotiated plea agreements because the defendants had violated the terms of the agreements by violating their probation. The defendants all appealed to the Pennsylvania Superior Court.

The Superior Court reversed the decision of the trial court. It found that the required periods of Megan’s Law registration were an implied part of the negotiations in each case. Further, the law on the enforcement of plea deals is well-settled. Although a plea agreement occurs as part of a criminal case, it remains contractual in nature and therefore must be analyzed under contract-law standards.

In evaluating whether a plea deal has been breached, the court must look at what the parties to the deal reasonably understood to be the terms of the agreement. When the Commonwealth makes a promise as part of a plea deal, the Commonwealth must live up to that promise. Here, the Commonwealth promised certain terms of registration in exchange for the guilty plea. Therefore, regardless of whether the defendants violated the plea deals by violating their probation, the Pennsylvania Supreme Court’s decision in Muniz prohibits the retroactive application of SORNA. Likewise, the legislature responded to Muniz by amending the SORNA statute to clarify that the previous registration terms which were in effect at the time of the offenses should again apply. Therefore, the Superior Court held that the defendants should be subject to the original periods of sexual offender registration and conditions imposed at the time of the plea bargains, if applicable.

This decision is incredibly helpful to those who have had their Megan’s Law Registration tiers retroactively increased. It also establishes that trial courts have the jurisdiction to re-classify offenders following Muniz. Previously, it was unclear whether defendants seeking relief would be barred by the jurisdictional and time-limit requirements of the Post-Conviction Relief Act and when those time limits would begin to run. The Superior Court here concluded that courts always retain the power to correct an illegal sentence. Because the Supreme Court found that SORNA is punitive and part of a criminal sentence, the trial courts retain the power to correct an improper order to register as a sex offender because the registration is part of the criminal sentence.

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PA Superior Court: Defendant in Sexual Assault Case May Testify That He Caught Complainant Cheating and Told Her Boyfriend

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The Pennsylvania Superior Court has decided the case of Commonwealth v. Palmore, holding that the trial court violated the defendant’s Confrontation Clause rights when it prohibited the defendant from testifying that he believed the complainant fabricated sexual assault allegations against him in order to discredit him and his attempts to tell the complainant’s boyfriend that he saw her performing oral sex on his roommate. This is one of only a handful of favorable appellate court rulings for the defense on whether a defendant may introduce any evidence relating to a rape complainant’s sexual history without violating Pennsylvania’s “Rape Shield Law.”

The Facts of Palmore

In Palmore, the defendant was a student at a college in Pennsylvania. One night, he hosted a party in his on-campus dorm room. He met the complainant during that party. The complainant claimed that two weeks later, the defendant forced himself on her, kissed her, placed one hand under her shirt and touched her breast. She claimed he then put his hand down her pants and touched her vagina. She testified that she protested throughout the sexual assault.

The Commonwealth arrested the defendant and charged him with indecent assault, disorderly conduct, and harassment. Prior to trial, the defendant moved to pierce the “rape shield” and admit evidence relating to the complainant’s past sexual conduct. Specifically, the defendant alleged that he had witnessed the complainant performing oral sex on his roommate. He argued that he confronted her about cheating on her boyfriend and that he later told her boyfriend about the cheating. He said that he both told the boyfriend verbally and then later discussed it with the boyfriend again via Facebook Messenger. He alleged that she fabricated the allegations of indecent assault against him so that her boyfriend would not believe him regarding the cheating incident with the defendant’s roommate. The trial court denied the motion to pierce the rape shield, finding that the evidence was not relevant and that the defendant could not introduce the evidence due to Pennsylvania’s Rape Shield Law.

The jury found the defendant guilty of all three charges. The trial court conducted a hearing to determine whether the defendant should have to register for life as a Sexually Violent Predator and concluded that he should, thereby requiring lifetime Megan’s Law registration. The trial court also sentenced the defendant to 228 to 729 days’ incarceration. The defendant appealed, arguing that the trial court erred in denying his motion to pierce the rape shield.

What is the Rape Shield Law?

Pennsylvania, like most states, has a Rape Shield Law. In general, a Rape Shield Law prevents a defendant from introducing evidence of a sexual assault complainant’s sexual history in order to discredit that witness. The purpose of the law is to prevent a defendant from introducing a complainant’s sexual history in order to smear the complainant and show that the complainant is promiscuous. The Pennsylvania statue reads:

Evidence of specific instances of the alleged victim’s past sexual conduct, opinion evidence of the alleged victim’s past sexual conduct, and reputation evidence of the alleged victim’s past sexual conduct shall not be admissible in prosecutions . . . except evidence of the alleged victim’s past sexual conduct with the defendant where consent of the alleged victim is at issue and such evidence is otherwise admissible pursuant to the rules of evidence.

The actual language of the statue appears to prohibit all evidence relating to a complainant’s sexual history that does not relate to a sexual history with the actual defendant charged with the crime. Courts have concluded, however, that the statute must be read in such a way that it will not violate a defendant’s rights under the Pennsylvania and United States Confrontation Clauses. Therefore, there are other exceptions to the Rape Shield Act beyond the exception explicitly mentioned in the statute.

What is the Confrontation Clause?

Both the Pennsylvania and United States Constitutions contain a Confrontation Clause. The Confrontation Clauses provide that in a criminal prosecution, the defendant must have the right to confront the witnesses against him or her. Confrontation has been interpreted by appellate courts as meaning cross-examination. Thus, courts, have held that rules that limit a defendant’s right to introduce relevant evidence through cross-examination of a complainant may violate the Confrontation Clause.

In order to harmonize the Rape Shield Act with the defendant’s right to confrontation, courts have found that a defendant may pierce the rape shield in certain cases when the evidence which the defendant seeks to introduce would show not that the complainant is promiscuous or sexually active but instead that the complainant has some motive to fabricate the allegations of sexual assault. Thus, the Rape Shield Law may not be used to exclude relevant evidence showing a witness’s bias or attacking a witness’s credibility.

In order to pierce the rape shield, the defendant must file a written motion in advance which contains the allegations that the defendant believes support introducing this type of evidence. If the defendant fails to file the motion in advance, the evidence may be excluded. After the defendant provides notice in the form of a written motion, the trial court must determine if the proffered reason for introduction of past sexual conduct evidence is merely speculation or conjecture. If it is, then the motion should be denied. If it is not, then the trial court must hold an in camera (non-public) hearing to evaluate the evidence.

In evaluating the evidence, the trial court must consider three factors:

  1. Whether the evidence sought to be admitted is relevant to the accused’s defense,
  2. Whether the evidence sought to be admitted is merely cumulative of evidence otherwise admissible at trial, and
  3. Whether the evidence which the accused wishes to introduce at trial is more probative than prejudicial.

If the answer to each question is yes, then the trial court must permit the defendant to introduce the proffered evidence. Otherwise, the court would violate the defendant’s right to confront his accuser.

The Superior Court’s Ruling in Palmore

The Superior Court ruled that the evidence should have been admitted. The trial court held the hearing, so the court must have concluded that the evidence was not mere conjecture or speculation. The Superior Court also concluded that the evidence was relevant because it went directly to the complainant’s credibility. It gave her a reason to fabricate the allegations against the defendant. It was not cumulative because there was no other way for the defendant to establish that the complainant had fabricated the allegations or had a reason to fabricate the allegations.

However, the trial court had found that the evidence was more prejudicial than probative. The Superior Court rejected this analysis; it found that the defendant was not seeking to impugn the complainant’s character or label her as a promiscuous college student. Instead, he sought to introduce the evidence to get to the truth by challenging her credibility. Thus, the evidence would not have violated the Rape Shield Law by shifting the focus of the trial from  whether the defendant committed the crime charged to a trial on the “virtue and chastity of the victim.” The evidence offered was key to the defendant’s defense, and he had no other real opportunity to challenge the complainant’s credibility. Therefore, it should have been admitted, and the trial court violated his Confrontation Clause rights by precluding it. The defendant will receive a new trial at which the evidence will be admissible.

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If you are facing criminal charges, we can help. Our award-winning Philadelphia criminal defense attorneys have successfully defended thousands of clients. We have represented clients in serious cases involving allegations of rape, homicide, aggravated assault, robbery, and other major felonies. We are experienced and understanding criminal defense lawyers who will use our skill and expertise to fight for you. We offer a free 15-minute criminal defense strategy session to any potential client. If you are facing criminal charges or may be under investigation, call 267-225-2545 to start building your defense today.