Drug Charges

PA Superior Court: A decade in jail is too much time for selling a pill and a half to another inmate

Philadelphia Criminal Lawyer Zak Goldstein

Philadelphia Criminal Lawyer Zak Goldstein

The Pennsylvania Superior Court has decided the case of Commonwealth v. Sarvey, holding that it is unreasonable to sentence a defendant to over ten years’ incarceration for attempting to distribute one and one-half pills of a controlled substance to another inmate while in prison. The Superior Court is often reluctant to overrule even the harshest of excessive sentences, so this is a great opinion for the defense which shows that there are some limits to a judge’s discretion in sentencing a defendant.

Commonwealth v. Sarvey

On July 26, 2011, the defendant was incarcerated at Jefferson County Correctional Facility when she attempted to give one-half of a tablet of Oxycodone and a tablet of Ambien to another inmate. The prison recorded the attempted sale on video. The defendant hid the pills under a commissary form and slid them under cell door toward another inmate’s cell.

A corrections officer noticed the papers being pushed underneath the defendant’s cell door and attempted to pick them up. The defendant refused to release the papers. After a struggle, the officer was able to take the papers away from her. The officer handed the form back to the defendant, and as the officer walked away she noticed a baggie containing two pills in the place where the paper had been. The officer confiscated the baggie.

The defendant was subsequently charged with two counts of possession with intent to deliver a controlled substance (hereinafter “PWID”), two counts of possession of a controlled substance by an inmate (hereinafter “possession by an inmate”), two counts of controlled substance contraband to confined persons prohibited (hereinafter “controlled substance to prison”) and two counts of criminal attempt. Some of these charges were added prior to trial when the Commonwealth filed a motion to amend the information on the eve of trial. On April 16, 2012, a jury found the defendant guilty of all charges.

At sentencing, the trial court sentenced the defendant to consecutive terms of incarceration on the PWID convictions (one to three years for one PWID count and one and one-half years to three years to three years for the second PWID count). The trial court further imposed consecutive terms of incarceration for each count of possession by an inmate (one and one-half years to three years on each count), and a term of incarceration of two to five years for each count of controlled substance to prison.

Unfortunately for the defendant, she was also on the trial judge’s probation for four other cases. The trial judge then revoked her probation on those cases and sentenced her to a term of confinement of one to two years plus five years of probation. In total, the defendant received a sentence of ten and one-half to twenty-four years of incarceration followed by five years of probation. The defendant then filed an appeal.

The Superior Court Appeal

The defendant filed a direct appeal to the Superior Court. In the direct appeal, the defendant only raised the issue that the trial court erred in granting the Commonwealth’s motion to amend the information to add charges on the eve of trial. However, the Superior Court found that the appeal was without merit. The defendant also petitioned the Pennsylvania Supreme Court to review her appeal, but the Court declined to do so.

With her appeals denied, the defendant then filed a Post-Conviction Relief Act (“PCRA”) petition alleging that her trial and appellate attorneys were ineffective in failing to challenge her sentence as excessive on appeal. At the PCRA hearing, her trial attorney testified that he did not object to her sentence nor did he file a post-sentence motion to reconsider the sentence. The trial court denied the PCRA Petition, and the defendant appealed the denial of the PCRA Petition to the Superior Court. She raised a number of issues in her appeal of the PCRA Petition, but she won relief only on the failure to appeal the excessive sentence.

Can you file a PCRA against an appellate attorney?

Yes. A defendant is entitled to competent representation at all stages of their criminal case and not just the trial. If the court finds that an appellate attorney provided the ineffective assistance of counsel when handling a defendant’s appeal, that defendant could be entitled to another appeal. For a more detailed summary of Pennsylvania’s Post-Conviction Relief Act, please see our other articles where we discuss PCRAs in more detail (https://goldsteinmehta.com/blog/important-changes-to-pas-post-conviction-relief-act-pcra).  

Can I appeal my sentence in Pennsylvania?

Yes. In Pennsylvania, if a defendant is found guilty of a crime, they must be sentenced to a minimum and maximum sentence. Obviously, some crimes are more serious than others and carry the possibility for a longer sentence. For example, a felony of the first degree has a maximum of twenty years’ incarceration whereas a misdemeanor of the first degree has a maximum of five years’ incarceration. However, just because someone is found guilty of a crime does not mean that a judge has free rein to give them the longest sentence allowed by statute. Additionally, just because a defendant was found guilty of multiple convictions does not mean that a judge can give maximum consecutive sentences on each of the charges.

When fashioning a sentence, a judge is supposed to take several factors into consideration into consideration. First, the sentencing court must consider the sentencing guidelines for a particular defendant. The sentencing guidelines analyze the severity of the offense (also known as the offense gravity score) and the criminal history of the defendant (also known as the prior record score). Again, for a more detailed analysis of Pennsylvania sentencing guidelines, please refer to our Pennsylvania Sentencing Guidelines blog(https://goldsteinmehta.com/blog/i-got-arrested-what-am-i-looking-at-an-explanation-of-the-pa-sentencing-guidelines).

However, courts should consider additional factors when sentencing a defendant. For example, the sentencing court should consider factors such as the age of the defendant; the facts of the case; whether the crime involved violence; whether the defendant is a threat to the community; the rehabilitative needs of the defendant, etc. It should be noted that appellate courts are unlikely to overturn a defendant’s sentence. Judges are given an incredible amount of discretion when fashioning a sentence. In order to successfully appeal a sentence, the sentencing court must have been unduly harsh, as in Sarvey, in order for a defendant to successfully win an appeal on grounds that the sentencing court abused their discretion.

Sarvey’s sentence was excessive

In Sarvey, the Superior Court found that the defendant’s sentence was clearly unreasonable and that her attorney was ineffective for not objecting to it and filing a post-sentence motion. The Superior Court found that her attorney did not have a reasonable basis for his failure to file a post-sentence motion and appeal the discretionary aspect of her sentence. The Superior Court further opined that although the court had a history with the defendant and that distributing narcotics in prison is particularly dangerous, her sentence was “unquestionably harsh” as she had merely attempted to provide 1.5 pills to another inmate. Thus, a sentence with a minimum of more than ten years for such conduct was simply too harsh and an abuse of the trial court’s discretion. The Superior Court noted that although the charges do not technically merge for sentencing purposes, they are undeniably very similar and intended to punish the same type of conduct. Therefore, defense counsel was ineffective in failing to appeal the original sentence. Accordingly, Sarvey will receive a new sentencing hearing.

Facing Criminal Charges? We Can Help.

Goldstein Mehta LLC Criminal Defense Attorneys

Goldstein Mehta LLC Criminal Defense Attorneys

If you are facing criminal charges or 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: Fire Risk from Growing Marijuana at Home Does Not Support Conviction for Risking Catastrophe or Recklessly Endangering Another Person

Zak Goldstein - Criminal Defense Lawyer

Zak Goldstein - Criminal Defense Lawyer

The Pennsylvania Superior Court has decided the case of Commonwealth v. McCoy, holding that growing marijuana in one’s home and the corresponding risk of fire do not provide enough evidence to support a conviction for Risking a Catastrophe or Recklessly Endangering Another Person.

Commonwealth v. McCoy

On December 22, 2015, Philadelphia police officers were called to a residence in Philadelphia. At the location, they met the defendant, who was complaining about trespassers. These trespassers were relative’s of the defendant’s recently deceased girlfriend. The defendant claimed that they were on scene and taking his property. While speaking to individuals in the apartment, one of the officers was informed by the mother of the defendant’s late girlfriend that the defendant was growing marijuana in his apartment.

One of the officers then asked the defendant where the marijuana was, and the defendant showed the officer to a closet in the front bedroom. The closet door was closed, but the officer noticed bags of potting soil and fans in the bedroom. The defendant then opened the closet door, revealing the marijuana plants inside. The defendant stated that he just grew the marijuana as a hobby and did not sell it. The officer then placed Appellant under arrest and called for a search warrant to be prepared. The police subsequently recovered 31 marijuana plants and one heat lamp. Notably, the defendant’s home is about fifteen feet away from his neighbor’s home. There was also a first floor apartment in the house, but no one was living there at the time.  

Police arrested the defendant and charged him with Risking a Catastrophe, Possession of Marijuana, and Recklessly Endangering Another Person (“REAP”). The defendant filed a pre-trial motion to suppress his statements and the physical evidence. The trial court denied the motions and convicted the defendant following a bench trial.

At this trial, the Commonwealth called a fire marshal who was qualified as an expert in the field of fire prevention. He testified that the defendant had used ordinary household extension cords to plug in the lamps in the closet. He opined that this created a dangerous condition because the lamp could draw a greater voltage than that which the cord could handle. Additionally, the fire marshal stated that in his expert opinion, the defendant’s marijuana growing operation represented a risk of causing a fire and that it was “an extreme fire hazard.” However, the fire marshal admitted that he was not familiar with the particular type of sun lamp used by the defendant, and he did not see evidence of transformers or an irrigation system in the operation.

The defendant also testified at his trial. He testified that he used a fluorescent lamp which did not generate heat in his marijuana growing operation. He also stated that the metal foil used in his closet was to reflect light, not heat, to the marijuana plants. He further stated that he watered the plants with a spray bottle and that he and his late girlfriend would monitor them in the morning and evening. 

At the conclusion of the trial, the court found him guilty of Risking a Catastrophe, Possession of Marijuana, and REAP. He received a sentence three years’ reporting probation. He appealed, arguing that the Commonwealth presented insufficient to convict him of either Risking a Catastrophe or REAP.  

What is Risking a Catastrophe?

Risking a Catastrophe is a serious felony charge in Pennsylvania. 18 Pa.C.S.A. § 3302(b) provides:

“[a] person is guilty of a felony of the third degree if he recklessly creates a risk of catastrophe in the employment of fire, explosives, or other dangerous means listed in subsection (a) of this section (i.e. radioactive or poison materials).”

The fact that a catastrophe did not occur is not a defense to this statute. A catastrophe is defined as widespread injury or damage. However, courts have previously held that a risk of fire involving a single residence is not sufficient to establish a “catastrophe” for purposes of the statute. However, courts have held that if one has a methamphetamine lab in his or her home it is sufficient to convict a defendant of Risking a Catastrophe.

What is REAP?

18 Pa.C.S.A. § 2705 provides:

“[a] person commits a misdemeanor of the second degree if he recklessly engages in conduct which places or may place another person in danger of death or serious bodily injury.”

To be convicted of REAP, one must have a conscious disregard of a known risk of death or great bodily harm to another person. The apparent ability to inflict harm is not sufficient to convict someone of REAP. Unlike most crimes, this is not a specific intent crime. As such, it is easier for the Commonwealth to prove the mens reas for REAP which is, unsurprisingly, recklessness.

The Superior Court Reverses the Convictions for REAP and Risking a Catastrophe.

After reviewing the record, the Superior Court reversed the convictions for REAP and Risking a Catastrophe. The Superior Court opined that though the defendant’s actions created a fire hazard, the record did not support that it had the potential for widespread injury or damage. Specifically, because he lived alone and the closest neighboring home was not in real danger of being engulfed by a potential fire from his house, he had not taken actions which sufficiently risked a catastrophe to justify a conviction under the statute.

The Superior Court further held that his actions were not “reckless.” Although the fire marshal described the defendant’s actions as “inadequate” to prevent a fire hazard, the Superior Court found that the defendant had taken steps that showed he was not being reckless. Specifically, the defendant watered the plants and monitored them twice a day. Further, the metal foil used in his closet was to reflect light, not heat. As such, according to the Superior Court, the defendant was not “reckless” and therefore was not guilty of REAP. Consequently, his convictions were reversed and he will be re-sentenced on his unchallenged possession of marijuana conviction.       

Facing Criminal Charges? We Can Help.  

Philadelphia Criminal Defense Lawyers Zak Goldstein and Demetra Mehta

Philadelphia Criminal Defense Lawyers Zak Goldstein and Demetra Mehta

If you are facing criminal charges or 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, Possession with the Intent to Deliver, Robbery, 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 Supreme Court: Consent to Search Car Does Not Necessarily Include Consent to K9 Search

Criminal Lawyer Zak Goldstein

Criminal Lawyer Zak Goldstein

The Pennsylvania Supreme Court has decided the case of Commonwealth v. Valdivia, holding that a motorist’s consent to a police search of his car does not automatically include the consent to detain the motorist for 40 minutes and then conduct a canine search. Instead, the scope of the search by the police should have been limited to that for which a reasonable person expected he or she had provided consent.

The facts of Valdivia

In Valdivia, Pennsylvania State Police Troopers were on patrol in a marked police cruiser on Interstate 80 in Centre county, PA. At some point, they drove behind the defendant, who was driving a white minivan with Michigan plates. After two miles, they saw the van change lanes without using a turn signal. They decided to pull the defendant over. The defendant complied and pulled over to the side of the road.

The troopers both approached the vehicle. One of the troopers asked for the defendant’s license, registration, and proof of insurance. The defendant responded that he was about to run out of gas, but he provided the trooper with his Florida driver’s license and a rental agreement for the van. As troopers so often do, the trooper testified that the defendant seemed nervous and that his hands were shaking when he provided the documentation.

The troopers then began asking the defendant about his travel plans. He explained that he was on his way to New Jersey to visit family and provided an elaborate story about how he ended up renting a minivan instead of flying from Florida. From outside of the van, the trooper was able to see two large boxes wrapped in Christmas paper in the back of the van. The trooper found it odd that the gifts had no markings from an airline and that they were not banged up. He also later testified that drug traffickers often wrap up containers of drugs in Christmas paper during the holidays. The trooper also had concerns about the fact that the van had been rented thirty miles away from the airport for a one-way trip. He then ran the defendant’s record and found that he had priors for possession with the intent to deliver.

The troopers contacted a State Police K9 officer who was not currently on duty and asked him to come to the scene. While they waited for him, they told the defendant to get out of the van. They explained that they were going to provide him with a written warning for failing to use his turn signal when changing lanes. After returning his documentation, the trooper asked the defendant if he would answer a few more questions. The defendant said that he needed to get gas, but he would answer a few more questions. The troopers then continued to grill him about his travel plans and the paperwork for the van. The defendant’s story changed a little bit, the troopers became increasingly suspicious, and they then asked for consent to search the van. The defendant gave verbal consent first and then signed a written consent form, two things which you should virtually never do. The troopers had not told the defendant that a K9 officer was on the way.

Because it was cold, the troopers generously asked the defendant if he would like to wait in the back of the patrol car while they searched the minivan. The troopers then waited for the K9 officer; they did not start searching the minivan in the meantime. When the K9 arrived, the troopers removed the Christmas boxes from the minivan and had the K9 sniff them. The K9 “alerted",” suggesting that they were drugs in one of the boxes. The troopers opened the boxes and found lots of marijuana. They seized the marijuana, a mobile smartphone, and a tablet, and they arrested the defendant. Prosecutors charged him with possession of a controlled substance, possession with the intent to deliver, and possession of drug paraphernalia.

The Motion to Suppress - Were there limits to the consent to search?

The defendant filed a motion to suppress the marijuana, arguing that although he had consented to a normal search of the minivan, he had not agreed to wait for 40 minutes and then allow a K9 search. The trial court denied the motion. It found that the defendant voluntarily consented to the search and that it was not the product of police coercion. Further, it found that the defendant consented to the K9 search because he had not placed any limits on the scope of the search when he authorized the troopers to search his car. The court reasoned that because he was engaged in the transportation of drugs, he should have realized that troopers may use a dog for the search. The defendant then proceeded by way of bench trial, was found guilty of all charges, and sentenced to 11.5 to 23 months in jail followed by 30 days of probation.

The defendant appealed to the Superior Court. The Superior Court agreed with the trial court and affirmed the trial court’s decision. The Superior Court found it to be a close case, but ultimately ruled against the defendant. The Superior Court concluded that there is nothing about a K9 search which differentiates it from a human search when it comes to the issue of consent to search. The defendant then filed a Petition for Allowance of Appeal to the Pennsylvania Supreme Court, and the Court accepted the case.

Consent to search does not automatically include consent to a K9 sniff

The Pennsylvania Supreme Court reversed the suppression court’s decision. It found that the consent to search provided by the defendant did not automatically include the consent to wait 40 minutes and then be subjected to a K9 sniff. In Pennsylvania, police typically need a search warrant or probable cause in order to search a motor vehicle. However, one exception to the probable cause requirement is that police may conduct a search without any level of reasonable suspicion or probable cause when the defendant agrees to it. Notably, New Jersey has a different rule in which police must have reasonable suspicion in order to request consent to search.

When is consent to search valid?

Although police need not have any level of suspicion in order to legally conduct a consensual search, there are some limitations with which they must comply even during a consent search. For example, they must have obtained the consent voluntarily. If the police obtained the consent by threatening to shoot the defendant, then that would probably not be voluntary consent. Additionally, the search must be limited to the scope provided by the suspect. This means that if the suspect agrees to a search of one room but not another, police cannot search that other room without obtaining a warrant or unless some other exception applies. When there is some ambiguity to the valid scope of the search, the scope is determined by what would be objectively reasonable. This means the court does not look to what the defendant actually intended or what the officer understood, but instead what a reasonable person would have understood by the exchange between the officer and the person.

Given the scope limitations on consent searches, the issue became whether the defendant should have reasonably expected that police would detain him for nearly an hour and then conduct a K9 search. The Supreme Court ultimately found that he should not have reasonably expected such police behavior. Courts have long held that a K9 search is different from a regular search, and the police did not mention to the defendant that they had a K9 on the way or that he would have to wait for such an extended period of time. The defendant gave two human officers permission to search his car. There was no K9 or K9 handler present at the time, and nothing about the interaction suggested that one was on his or her way. Under these circumstances, a reasonable person would not have anticipated a K9 search of the boxes. Accordingly, the troopers exceeded the scope of the defendant’s consent, and the trial court should have granted the Motion to Suppress.

Goldstein Mehta LLC Criminal Defense Attorneys

Goldstein Mehta LLC Criminal Defense Attorneys

FACING CRIMINAL CHARGES? WE CAN HELP.

If you are facing criminal charges or 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 and dismissals in cases involving charges such as Conspiracy, Possession with the Intent to Deliver, Aggravated Assault, Sexual 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: Villanova University Campus Safety Officers Can Search Your Room

Criminal Defense Lawyer Zak Goldstein

Criminal Defense Lawyer Zak Goldstein

The Pennsylvania Superior Court has decided the case of Commonwealth v. Yim, holding that the Villanova Public Safety Officers are not state agents for purposes of the Fourth Amendment. This is a significant decision for those who attend private universities which do not have police forces because it means that campus safety officers may be able to search a dorm room without a search warrant.

Commonwealth v. Yim  

On February 13, 2016, Villanova University’s Public Safety Officers became engaged in violent confrontations with two resident students and a female visitor who later admitted to ingesting LSD. These three individuals were restrained by the public safety officers until Radnor Police Officers arrived on scene. One of the residents lived at Good Counsel Hall, which is located on Villanova’s campus, with the defendant. It is important to note that although Villanova has now established an actual police force, at the time, its officers were not police. They did not have arrest powers or carry weapons or handcuffs. Further, Villanova is a private university.

As a condition of living at Good Counsel Hall, the defendant had signed a housing contract in which he consented to a search of a dorm room where it has been determined by public safety officers that items or individuals in a particular room pose a possible safety or health risk to the community. Later that day, the Villanova University Director of Public Safety was advised of the events that transpired involving the defendant’s roommate. The administration subsequently ordered a search of the defendant’s room.

Prior to searching the room, the administrators unsuccessfully attempted to contact the defendant by telephone. The Director of Public Safety, along with two Public Safety Officers, unlocked and entered the dorm room. Once inside, they observed contraband and cash strewn throughout the room. They saw a syringe in plain view on top of a desk. The defendant’s passport, cash, LSD “stamps”, marijuana, $8,865.00, and other drug paraphernalia was also found on and in the defendant’s desk.

After the contraband was recovered, the Director of Public Safety called the Villanova University dispatcher and asked him to contact the Radnor Police Department to report the discovery of the drugs and paraphernalia. The Radnor Police arrived on scene, but they remained in the hall outside the room. The police officers never entered the room nor did they participate in the search. After the public safety officers searched the room, they turned over the contraband and other items to the Radnor Police. The Public Safety Officers also provided an investigative report, which included photographs, for future use in University administrative proceedings. The police then obtained an arrest warrant for the defendant. He was eventually arrested and charged with possession of a controlled substance, possession of drug paraphernalia, and possession with the intent to deliver (“PWID”).

The defendant filed a motion to suppress the evidence seized from his person and the dorm room. The trial court denied the motion, ruling that the public safety officers did not need a search warrant to search the dorm room because they were not law enforcement officers and Villanova was not a public university. The trial court found the defendant guilty after a non-jury trial and sentenced him to a term of three to 23 months’ incarceration plus four years probation.

What is the Fourth Amendment?

The Fourth Amendment provides:

The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.

The Fourth Amendment often provides a defense to criminal charges relating to drug possession, illegal gun possession, or the possession of other contraband because it prevents the prosecution from introducing evidence at trial if the evidence was seized illegally. However, one significant limit on the Fourth Amendment is that it does not apply to searches and seizures conducted by other private citizens. It only protects citizens from the government; it does not protect them from private actors. Thus, the Fourth Amendment may be invoked as part of a motion to suppress evidence when the when a government actor like a police officer enters an individual’s home without a search warrant or stops someone without probable cause or reasonable suspicion. In this case, however, the officers who seized the contraband from the dorm room did not work for the government. They were not police officers performing a government function and Villanova is a private school.

Can the Fourth Amendment Apply to Non-State Actors?

In some circumstances, the Fourth Amendment can apply even to non-government employees. For example, the Fourth Amendment’s protections against unreasonable searches and seizures do apply to non-state actors when private individuals act as an instrument or agent of a state. Here, the defendant argued at the motion to suppress that Villanova’s public safety department had assumed a governmental function and essentially acted as the police. Accordingly, the defense argued that the public safety officers should be treated as state actors. Unfortunately, cooperation with the authorities alone does not constitute state action. The mere fact that the police and prosecutors use the results of a private actor’s search does not transform the private action into a state action. Instead, it must be shown that the relationship between the person committing the wrongful acts and the state is such that those acts can be viewed as emanating from the authority of the state. This means that if a college or university forms an actual police department with certified officers who have arrest powers, then the Fourth Amendment should apply to those officers. Likewise, the Fourth Amendment may apply to the public safety department of a public university because the officers would be government employees. Here, however, the officers were not actual police officers or government employees.

Can Campus Safety Officers Search a Dorm Room Without a Warrant?

Ultimately, the Pennsylvania Superior Court affirmed the suppression court’s denial of the defendant’s motion to suppress. The Superior Court found that the University conducted the search on its own terms and in accordance with its own policies aimed at preserving student safety. The public safety department did not act jointly with the police or at the behest of the police in carrying out the search. Additionally, the public safety department had not assumed a governmental function such that it should be subject to the Fourth Amendment because the Radnor Township Police Department still served as the actual police force on university property. The court denied the appeal, and the defendant will not receive a new trial.

Facing Criminal Charges? We Can Help.

Goldstein Mehta LLC

Goldstein Mehta LLC

If you are facing criminal charges or 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, Possession with the Intent to Deliver, 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.