Philadelphia Criminal Defense Blog

Zak Goldstein 2/28/26 Zak Goldstein 2/28/26

PA Supreme Court: Resentencing Counsel Ineffective for Failing to Object to Prejudicial “Serial Killer” Evidence in Death Penalty Case

Criminal Defense Lawyer Zak T. Goldstein, Esquire

The Pennsylvania Supreme Court has decided the case of Commonwealth v. Smith, No. 815 CAP (Pa. Feb. 26, 2026), holding that resentencing counsel was ineffective for failing to adequately object to the Commonwealth’s evidence and argument portraying the defendant as an aspiring serial killer during a capital resentencing hearing. The Court reversed the PCRA court’s order and remanded the matter for a new penalty-phase hearing. The unanimous decision was authored by Justice Brobson.

The Facts of Commonwealth v. Smith

In November 1994, Eileen Jones and the appellant, Wayne Smith, left together in a car borrowed from Smith’s nephew. Smith returned the car later that evening, and the next day, he told his brother that he had murdered Jones by choking her in a nearby park. Jones’s body was discovered on November 22, 1994, and the county medical examiner concluded the cause of death was strangulation. Police also recovered newspaper articles about the recovery of Jones’s body from Smith’s home.

A jury found Smith guilty of first-degree murder and sentenced him to death. Smith’s conviction and sentence were affirmed on direct appeal by the Pennsylvania Supreme Court in Commonwealth v. Smith, 694 A.2d 1086 (Pa. 1997). Smith then filed a PCRA petition, and the Supreme Court ultimately vacated the death sentence and remanded for a new penalty-phase hearing after finding that counsel had provided ineffective assistance. Commonwealth v. Smith, 995 A.2d 1143 (Pa. 2010).

At the 2012 resentencing hearing, the jury again sentenced Smith to death after finding the aggravating circumstance of a prior voluntary manslaughter conviction outweighed the mitigating circumstances of emotional distress and an abusive childhood. The Supreme Court affirmed the sentence on direct appeal in Commonwealth v. Smith, 131 A.3d 467 (Pa. 2015), and the United States Supreme Court denied certiorari.Smith v. Pennsylvania, 580 U.S. 830 (2016).

The “Serial Killer” Evidence at the Resentencing Hearing

At the center of this appeal was highly inflammatory evidence the Commonwealth introduced at the 2012 resentencing hearing. Prior to the original trial, Smith had actually filed a motion in limine to exclude any reference to his alleged interest in being a serial killer, and the defense had successfully precluded the Commonwealth from pursuing that theory at the original trial and sentencing in 1995.

However, at the 2012 resentencing hearing, the Commonwealth sought to introduce testimony from Sonya Rollins, Smith’s ex-girlfriend, about Smith’s reading habits. The prosecution also asked the resentencing court to allow Rollins to testify that Smith read books about murder and crime, including titles such as “The Perfect Crime” and “How to Get Away with the Perfect Crime.” The Commonwealth argued this evidence was relevant to show intent and to rebut Smith’s anticipated mitigation evidence regarding mental illness and an abusive childhood.

Resentencing counsel objected to the Commonwealth’s motion in limine, arguing that evidence about reading habits was inadmissible character evidence that amounted to nothing more than smearing his client. However, the resentencing court permitted the testimony. Critically, resentencing counsel did not renew his objection when Rollins actually took the stand and testified, did not object to testimony from Smith’s brother Jeffrey about Smith’s alleged interest in serial killers, did not object to a police detective reading from Smith’s statement about fantasizing about being a serial killer, and did not object to the prosecutor’s repeated references to the serial-killer theme in both opening and closing arguments.

The prosecutor made this evidence the centerpiece of her case for death, arguing in her opening that Smith had been planning the murder for 14 years and comparing him to Ted Bundy. In closing, the prosecutor urged the jury to give Smith “his recognition” and “his attention” — referring to his alleged desire for the notoriety of a serial killer.

The PCRA Proceedings

Smith timely filed a PCRA petition in 2017 arguing that resentencing counsel was ineffective for failing to object to the serial-killer evidence. The PCRA court ultimately dismissed the petition after a hearing, finding that counsel’s decision not to continue objecting after the court granted the Commonwealth’s motion in limine was a reasonable tactical decision. The PCRA court also concluded that Smith had not established prejudice because the serial-killer evidence was only a small part of the Commonwealth’s overall case.

The Pennsylvania Supreme Court’s Decision

The Supreme Court unanimously reversed, finding that Smith had satisfied all three prongs of the ineffective assistance of counsel standard under Commonwealth v. Cooper, 941 A.2d 655 (Pa. 2007).

Arguable Merit: The Court agreed with Smith that the reading-material and serial-killer evidence were irrelevant to the resentencing proceedings. The Court noted that the sole issue for the jury was whether to sentence Smith to death or life imprisonment, and that Smith’s intent to kill Jones, which the Commonwealth claimed the reading evidence proved, had already been established by his first-degree murder conviction. As to the Commonwealth’s second justification, that the evidence rebutted Smith’s mitigation evidence regarding mental illness and an abusive childhood, the Court found it unclear how reading books about murder would undermine evidence that Smith was abused as a child, suffered from post-traumatic stress disorder, or was substantially impaired. Whatever minimal probative value the evidence may have had was outweighed by the danger of unfair prejudice under Pa.R.E. 403.

Reasonable Basis: The Court rejected the argument that resentencing counsel acted reasonably by not continuing to object after the motion in limine was granted. The Court highlighted two important factors: first, the Supreme Court itself had previously determined in Smith III that resentencing counsel failed to properly object to the reading-material evidence and had therefore waived the issue on direct appeal. Second, the Commonwealth’s motion in limine did not address Smith’s alleged desire to be a serial killer. The resentencing court never actually ruled on that evidence, and yet counsel failed to object to any of the serial-killer testimony or the prosecutor’s inflammatory use of it in opening and closing arguments.

Prejudice: The Court found that the PCRA court had improperly applied a “harmless error” standard rather than the correct prejudice standard for ineffective assistance claims. Under the proper standard, Smith needed to show a reasonable probability that at least one juror would have concluded that the aggravating circumstance did not outweigh the mitigating circumstances. The Court concluded that this standard was met, noting that the Commonwealth had made the serial-killer evidence the central theme of its case for death, repeatedly referring to it throughout the proceedings. The Court also noted that the resentencing jury had initially reported that it was unable to reach a unanimous verdict before ultimately sentencing Smith to death, which further bolstered the finding of prejudice. The Court rejected the Commonwealth’s argument that because the original jury (which did not hear the serial-killer evidence) also sentenced Smith to death, the evidence could not have been prejudicial, explaining that the two sentencing hearings were not comparable; the first lasted one day with a 39-page transcript, while the resentencing hearing spanned four days with hundreds of pages of testimony.

The Takeaway

This decision is significant for several reasons. First, it reinforces the principle that evidence admitted at a penalty-phase hearing must actually be relevant to the issues the jury is deciding, namely, whether aggravating circumstances outweigh mitigating circumstances. Evidence that serves primarily to paint a defendant in a negative light without bearing on the actual sentencing determination is inadmissible, particularly where its prejudicial effect substantially outweighs any probative value under Pa.R.E. 403.

Second, the decision clarifies the obligations of counsel at a resentencing hearing. The Court made clear that an attorney cannot simply stop objecting to inadmissible evidence after an initial objection is overruled. Counsel must preserve objections when evidence is actually introduced and must object to improper arguments by the prosecution.

Third, the Court’s analysis of the prejudice prong is noteworthy. The Court distinguished between the “harmless error” standard applicable on direct appeal and the “prejudice” standard applicable to ineffective assistance claims under the PCRA, noting that the PCRA court had improperly conflated the two. In a capital case, the proper question is whether there is a reasonable probability that at least one juror would have reached a different conclusion on the weighing of aggravating and mitigating circumstances.

Facing Criminal Charges or Appealing a Conviction? 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, Aggravated Assault, Rape, Violations of the Uniform Firearms Act, and First-Degree Murder. We have also won on appeal. 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.

Zak Goldstein 2/12/26 Zak Goldstein 2/12/26

Third Circuit: A General Rule 29 Motion Does Not Preserve Specific Sufficiency of the Evidence Arguments for Appeal

The United States Court of Appeals for the Third Circuit has decided the case of United States v. Abrams, Nos. 24-1998, 24-3003 (3d Cir. 2026), holding that a bare, non-specific motion for judgment of acquittal under Federal Rule of Criminal Procedure 29 does not preserve every sufficiency of the evidence argument a defendant may later want to raise on appeal. This is an important decision for criminal defense lawyers practicing in federal court because it means that if you do not articulate your specific sufficiency challenges at trial, meaning provide the reasons for the sufficiency challenge at time time you move for a new trial or judgment of acquittal in the trial court, you will be limited to plain error review on appeal, which is an extremely difficult standard to meet.

The Facts of United States v. Abrams

The defendant in this case was convicted at a nine-day jury trial on 48 criminal counts, including wire fraud, mail fraud, aggravated identity theft, money laundering, unlawful monetary transactions, obstruction of justice, and making false statements. The charges arose from a scheme in which the defendant solicited investors for his clean energy startup by providing forged documents and false financial information. He then diverted investor funds for personal use, including purchasing a residence in South Carolina. The District Court imposed a 72-month prison sentence and ordered approximately $1.2 million in restitution.

The Rule 29 Motion at Trial

At the close of the government's case, the defendant moved for judgment of acquittal under Rule 29(a). The entire colloquy was remarkably brief:

THE COURT: Now that you are going to rest, are there motions?
DEFENSE COUNSEL: Yes. I move for judgment of acquittal on Rule 29(a). I waive argument.
GOVERNMENT COUNSEL: Subject to the pending stipulation, there's more than enough evidence in the record to justify all 48 counts in the indictment for a myriad of Title 18 offenses.
THE COURT: It's clear that the presentation of evidence so far if believed by the jury would certainly satisfy the government's burden of proof beyond a reasonable doubt, and so the Rule 29 motion is denied.

That was it. The defendant made no specific arguments about which elements of which offenses the government had allegedly failed to prove. He failed to identify any particular weaknesses in the evidence. He simply made a bare motion for an acquittal, with argument expressly waived.

On appeal, the defendant then raised a host of specific sufficiency arguments he had never presented to the trial court, including challenges to whether the government had proven the "money or property" element of fraud and whether the evidence established specific intent to defraud.

The Third Circuit's Holding on Preservation

The Third Circuit held that because Abrams made only a general, non-specific Rule 29 motion, he had not preserved his specific sufficiency arguments for appellate review. The Court applied plain error review instead of the de novo standard that ordinarily applies to sufficiency challenges.

The Court grounded its analysis in United States v. Joseph, 730 F.3d 336 (3d Cir. 2013), which drew a careful distinction between “issues” and “arguments.” Under Joseph, a single “issue” can encompass more than one discrete “argument.” To preserve a specific argument for appeal, a party must raise the same argument, not merely the same broader issue, in the district court. Merely raising an issue that encompasses the appellate argument is not enough.

The Court had previously applied this framework to Rule 29 motions in United States v. Williams, 974 F.3d 320, 361 (3d Cir. 2020), holding that when a Rule 29 motion raises specific grounds, all arguments not raised are unpreserved. But Williams expressly left open the question of whether a broadly stated Rule 29 motion, meaning one that raises no specific grounds at all, preserves all sufficiency arguments. In United States v. Johnson, 19 F.4th 248, 255 n.6 (3d Cir. 2021), the Court reaffirmed that Williams did not hold that a general Rule 29 motion preserves all sufficiency arguments.

In Abrams, the Court squarely decided that open question: a general Rule 29 motion does not preserve all sufficiency arguments later raised on appeal. This holding was driven by two principles of preservation doctrine. First, a party must put the district court “squarely on notice” of the point at issue, giving the court a chance to consider and resolve the matter in the first instance. Second, arguments must be sufficiently particularized and framed as specific arguments because judges “are not clairvoyant” and need not “anticipate and join arguments that are never raised by the parties.”

The Court acknowledged that several other circuits have held (often with little analysis) that a broadly stated Rule 29 motion without specific grounds preserves the full array of sufficiency challenges for appeal. The Third Circuit declined to follow that approach, finding it inconsistent with preservation principles and noting that it would create a perverse incentive for defense lawyers to say as little as possible in the district court in order to save their best arguments for appeal. The Court cited Judge Oldham's concurrence in United States v. Kieffer, 991 F.3d 630, 638-39 (5th Cir. 2021), which observed that this double standard “encourages defendants to say as little as possible in the district court and to save their good arguments as 'gotchas!' for appeal.”

What Happens Under Plain Error Review

Because Abrams had not preserved his sufficiency arguments, the Third Circuit reviewed them only for plain error under United States v. Olano, 507 U.S. 725 (1993). That standard requires a showing that (1) there was an error, (2) the error was plain, (3) the error affected substantial rights, and (4) not correcting the error would seriously affect the fairness, integrity, or public reputation of judicial proceedings. An insufficiency claim succeeds under this standard only where affirmance would produce a '“manifest miscarriage of justice,” meaning the record must be devoid of evidence of guilt or the evidence must be so tenuous that a conviction is shocking. United States v. Burnett, 773 F.3d 122, 135 (3d Cir. 2014). That is an extremely high bar. Unsurprisingly, the Third Circuit found no plain error in Abrams, noting that the evidence of fraud was overwhelming.

Facing Federal 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, Aggravated Assault, Rape, 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.

Zak Goldstein 1/23/26 Zak Goldstein 1/23/26

PA Supreme Court Fails to Reach Decision on Whether Search Warrant Required for Google’s Search Records

On December 16, 2025, the Pennsylvania Supreme Court issued a fractured decision in Commonwealth v. Kurtz, addressing a cutting-edge digital privacy question: do you have a reasonable expectation of privacy in the terms you type into a Google search bar?

The Court’s answer was “no”—at least for general, unprotected searches. However, because the decision was reached by a plurality (meaning a majority of justices did not agree on a single legal reasoning), it is not binding, and the ruling leaves significant questions unanswered regarding other types of digital data, particularly Internet Service Provider (ISP) records and IP address subscriber information.

Commonwealth v. Kurtz: The “Reverse Keyword” Warrant

In Kurtz, police were investigating a violent home invasion rape but had no DNA match or suspect. Investigators obtained a “reverse keyword search warrant” compelling Google to identify any IP addresses that had searched for the victim’s home address prior to the crime. Google identified an IP address associated with the defendant, leading to additional investigation, an eventual DNA match, and his conviction for rape in this case and other unsolved cases.

The defendant challenged the warrant, arguing he had a privacy interest in his search history and that the warrant provided no reason to believe that the perpetrator conducted a Google search at all let alone for the victim’s address. The trial court rejected this claim, and the defendant appealed. The Superior Court rejected the claim, too, finding that the defendant did not have a reasonable expectation of privacy in the records maintained by Google and that the police had obtained a legitimate search warrant even if he did. The defendant petitioned the Supreme Court for review, and the Pennsylvania Supreme Court agreed to hear the case. That Court, however, failed to reach a decision - three justices concluded that he had no reasonable expectation of privacy in the search records, three concluded that the warrant was fine and declined to address the REOP decision, and one justice would have granted the motion to suppress.

Accordingly, the Court affirmed the defendant’s conviction as it would have required four justices to vote to overturn it. In support of upholding the conviction, Justice Wecht authored an Opinion Announcing the Judgment of the Court (OAJC) which reasoned that the defendant did not have a reasonable expectation of privacy in the information and that investigators did not have to obtain a warrant at all because:

Voluntary Disclosure: By typing a query into Google, the user voluntarily discloses that information to a third party, meaning the user does not make an attempt to keep the information private.
Notice: Google’s privacy policy explicitly warns users that it collects search queries and shares them with law enforcement.
Lack of Necessity: The Court noted that using Google is a choice, not a necessity; users can use other search engines, libraries, or physical maps. They can also take steps to shield their identities and increase their privacy.

Accordingly, the defendant had no reasonable expectation of privacy in the search results.

Why Kurtz Is Not the Final Word

While Kurtz is a significant ruling for search history and the Superior Court’s ruling stands, it is not a total defeat for digital privacy rights in Pennsylvania for two key reasons:

1. It Is a Plurality Opinion: Crucially, the main opinion in Kurtz was joined by only three of the seven justices. When a court decides a case without a majority opinion, the holding is generally limited to the specific result of that case, and the legal reasoning is not fully binding precedent for future cases. This means the broad language about the third-party doctrine may not apply automatically to different factual scenarios or even similar scenarios.

2. It Is Limited to "Unprotected" Searches: The Court repeatedly stressed that its ruling applied only to “general, unprotected internet searches.” The justices expressly stated they were not deciding the privacy rights of users who utilize Virtual Private Networks (VPNs), private browsing modes, or encrypted browsers. Moreover, the courts have required legitimate search warrants where investigators seek to obtain bank records, phone records, and location data.

The Next Battleground: IP Addresses and ISP Records

The Kurtz decision creates a sharp distinction that defense attorneys can use in cases involving IP addresses and ISP subscriber records (the information “behind” the IP address, such as the customer's name and address).

In Kurtz, the Court emphasized that users have a choice: they can use Google, or they can use a privacy-focused competitor (like DuckDuckGo) or offline resources . However, this logic does not apply to IP addresses. Kurtz dealt with whether the police could obtain a list of IP addresses that had searched for a particular address. It did not address whether the police could obtain the information behind the resulting IP addresses without a search warrant, and in Pennsylvania, police often use administrative subpoenas to obtain that information rather than warrants. Whether they can do that under the Pennsylvania Constitution remains questionable for the following reasons:

Necessity vs. Convenience: You cannot use the internet without an IP address. It is technologically impossible. Unlike choosing a search engine, assigning an IP address is an involuntary condition of internet access, similar to how bank records or phone numbers are necessary to participate in modern life. Pennsylvania courts have long held that citizens do have privacy rights in bank records (Commonwealth v. DeJohn) and phone records (Commonwealth v. Melilli) because they are essential services.
The “Information Behind the IP”: Kurtz dealt with the content of a search communicated to Google. ISP inquiries deal with the identity of the user maintained by the internet provider. This information is generated automatically by the ISP, not voluntarily typed out by the user.

The Takeaway

At least for now, Commonwealth v. Kurtz establishes that if you type a search into Google without privacy protections, you cannot expect that search to remain private from police. However, because the decision relies heavily on the “voluntary” nature of using Google and Google’s explicit privacy warnings, it may not extend to the mandatory, automatic records generated by simply connecting to the internet via an ISP.

If you are facing charges based on digital evidence, IP address identification, or administrative subpoenas, the specific technical details of your case matter. The law is evolving rapidly, and a nuanced defense strategy is essential.

Facing criminal charges? We can help.

If you are under investigation or facing charges involving digital evidence, search warrants, or administrative subpoenas, we can help. We have successfully defended thousands of clients against criminal charges in courts throughout Pennsylvania and New Jersey. 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.

Zak Goldstein 1/18/26 Zak Goldstein 1/18/26

PA Superior Court Affirms Homicide by Vehicle while DUI Conviction Despite Inconsistent Verdicts

Commonwealth v. Kling

The Pennsylvania Superior Court has decided the case of Commonwealth v. Kling, affirming a defendant’s conviction for Homicide by Vehicle while Driving Under the Influence ("DUI") and Homicide by Vehicle.

The decision is significant for Pennsylvania DUI defense because it addresses “inconsistent verdicts.” Specifically, it addresses whether a defendant can be convicted of causing death while under the influence even if a jury acquits them of the specific DUI charge that involves being “impaired.”

The Facts of the Case

On April 20, 2023, the defendant was operating a motorcycle with a passenger on High Street in Limerick Township. At a red light, a Honda Accord driven by a third person pulled up beside him. When the light turned green, both vehicles accelerated rapidly toward a merge point about a quarter-mile away.

Witnesses and surveillance video established that neither driver would yield. As they approached the merge point, the Honda Accord overtook the motorcycle and merged into the left lane. The defendant struck the back of the Honda, causing the motorcycle to crash. His passenger was thrown from the bike and killed.

Police and EMS arrived and noted that the defendant appeared dazed, had pinpoint pupils, and was in pain. The defendant admitted he did not have a motorcycle license and the bike was unregistered. Toxicology reports later revealed fentanyl, amphetamine, and methamphetamine in the defendant’s blood.

The Inconsistent Verdicts

At trial, the Commonwealth charged the defendant with multiple counts of DUI. Notably, the jury acquitted him of DUI under 75 Pa.C.S. § 3802(d)(2), which requires proof that the defendant was under the influence to a degree that impaired their ability to safely drive.

However, the jury convicted him of DUI under § 3802(d)(1), which prohibits driving with any amount of a Schedule I controlled substance (or metabolite) in the blood, regardless of actual impairment. They also convicted him of Homicide by Vehicle while DUI. The conviction under § 3802(d)(1) did not require actual impairment. He received a lengthy state prison sentence.

The Appeal

The defendant appealed, arguing that the evidence was insufficient to support the Homicide by Vehicle while DUI conviction.

His argument was based on causation. To be convicted of Homicide by Vehicle while DUI, the Commonwealth must prove that the death was the "result of" the DUI violation. The defendant argued that because the jury acquitted him of the impairment charge (§ 3802(d)(2)), the Commonwealth failed to prove that he was actually impaired or that his intoxication caused the crash. He relied on Commonwealth v. Magliocco, arguing that an acquittal on a predicate offense should invalidate the greater offense.

The Superior Court's Decision

The Superior Court rejected the defendant’s arguments and affirmed the judgment of sentence.

1. Inconsistent Verdicts Are Permitted: The Court explained that inconsistent verdicts are generally allowed in Pennsylvania. The jury may have acquitted the defendant of the impairment DUI for reasons of leniency rather than a factual finding that he was sober. As long as the defendant was convicted of a violation of Section 3802 (in this case, having drugs in his system), the statutory requirement for the Homicide by Vehicle while DUI charge was met. The acquittal on the (d)(2) charge did not negate the elements of the homicide charge as a matter of law.

2. Evidence of Causation Was Sufficient: Even without a conviction on the impairment count, the Court found sufficient evidence that the defendant’s drug use caused the death. The Commonwealth presented expert testimony that high doses of methamphetamine can cause aggressive, impulsive, and risky driving.

The Court distinguished this case from Commonwealth v. Lenhart, where a driver with a high BAC crashed but there was no evidence of how the accident happened. Here, there was ample evidence of reckless driving. Specifically, the "deadly race" to the merge point. The Court concluded the jury could infer that the drugs in the defendant’s system contributed to this aggressive behavior, thereby causing the crash.

3. Recklessness Established: The Court also upheld the separate conviction for Homicide by Vehicle (which requires recklessness but not necessarily DUI). The Court held that the defendant’s decision to race another car to a merge point while unlicensed, driving an unregistered bike, and carrying a passenger without a helmet showed a conscious disregard for the value of human life.

Conclusion

This case reinforces that Pennsylvania courts will often uphold serious felony convictions even when jury verdicts appear logically inconsistent. It also highlights the danger of per se DUI charges (based solely on the presence of drugs in the blood) serving as the basis for Homicide by Vehicle convictions, provided the Commonwealth can link the drug presence to the driving behavior.

It remains true, however, that evidence of a DUI and a death is not enough for a homicide by vehicle while DUI conviction. Instead, the Commonwealth must show that the DUI actually caused the death. Here, the Court found that there was sufficient evidence. And even though the homicide by vehicle while DUI statute requires a DUI conviction and the defendant was acquitted of the DUI section that requires impairment, the Court affirmed the conviction because he was still convicted of a DUI. The Superior Court simply found no requirement that the defendant be convicted of any particular subsection and refused to draw any factual inferences from the jury’s acquittal.

The inconsistent verdict rule is hard to reconcile with common sense, and it is often inconsistently applied as there are some cases where it has been rejected. But in most cases, the courts will disregard an inconsistency verdict and instead look only at evidentiary sufficiency.

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