Philadelphia Criminal Defense Blog
Conviction for Possession of Firearm with Obliterated Serial Number Requires Intentional Modification of Serial Number
The prosecution must show more than the absence of a serial number. Instead, they must show that the defendant intentionally removed or modified the serial number on the gun.
The Pennsylvania Superior Court has just announced its decision in Commonwealth v. Ford, holding that a defendant may not be found guilty of 18 Pa.C.S. § 6110.2 (Possession of Firearm with Altered Manufacturer’s Number) when the numbers were altered through natural corrosion instead of intentional action. This decision protects individuals who own older firearms which have faded serial numbers. In Philadelphia, firearms offenses are taken very seriously, and prosecutors will often pursue severe sentences for defendants convicted of gun charges. If you are charged with possessing a firearm with an obliterated serial number or any offense involving a gun, it is crucial that you contact an attorney who is familiar with the law and is willing to fight for you.
Commonwealth v. Ford
In Ford, Philadelphia Police Officers received radio calls for a person bleeding and a person with a gun at 2010 Wilmot Street. The officers went to the backyard of that address, but no one was there. As they proceeded through an alleyway onto Ditman Street, the officers were then directed by bystanders to 4663 Ditman Street. While standing on the porch of that address, one of the officers heard screaming coming from inside the house. Based on the screaming, the high crime level in the neighborhood, and the radio call, the officers decided to knock on the door. When no one answered, the police entered the property without a warrant.
Once inside, the officers saw the defendant put an object which turned out to be a gun on the kitchen chair next to him. Officers promptly arrested the defendant after recovering the .38 caliber silver handgun. When officers looked at the gun, they could not see the manufacturer’s serial number. Because all modern firearms are required by law to have a serial’s number, the officers arrested the defendant and charged him with various Violations of the Uniform Firearms Act, including 18 PA C.S.A. § 6110.2 (possession of a firearm with an obliterated or altered serial number) and 18 PA C.S.A. § 6105 (possession of a firearm by a felon).
The defendant filed a Motion to Suppress, alleging that the gun should be suppressed because the police did not have a warrant when they entered the property. The Commonwealth responded that the officers were acting under the exigent circumstances exception. The exigent circumstances exception permits police to enter a house without a warrant under very limited circumstances – essentially, there must be a bonafide emergency or they must be in hot pursuit of a fleeing felon. After the officers testified to the reasons for entering without a warrant and argument from counsel, the trial court denied the Motion to Suppress. On appeal, the Superior Court affirmed, finding that though the police officers did not obtain a search warrant to enter the defendant’s home, the officers had probable cause and that there were exigent circumstances that warranted police entering his home given the radio call, the screaming, and the high crime nature of the area.
After the Motion to Suppress was denied, the defendant proceeded to trial by way of bench trial. Both the Commonwealth and the defense agreed that the serial number of the firearm had been obscured by corrosion as opposed to having been intentionally obliterated by the defendant. Nonetheless, the trial court found the defendant guilty of both possession of a gun by a felon and possession of a gun with an obliterated serial number, and the court sentenced him to a lengthy state sentence. The defendant appealed, arguing both that the trial court should have granted the Motion to Suppress and that the obliterated firearm statute does not make it illegal to possess a firearm where the serial number naturally wore away over the years and was not intentionally removed.
What is § 6110.2 (possession of a gun with an obliterated serial number)?
§ 6110.2 is one of several statutes that collectively form the Pennsylvania Uniform Firearms Act. In Philadelphia, charges brought under the Act are commonly referred to as VUFA charges, or Violations of the Uniform Firearms Act. § 6110.2 makes it illegal to possess a firearm which has the manufacturer’s number integral to the frame or receiver altered, changed, removed or obliterated.” Further, unlike some of the other VUFA statutes, § 6110.2 does not require that the firearm be operable. Also, it is not a defense to § 6110.2 that the defendant possessed the gun at his or her residence or place of business, making the statute very different from § 6106 (possessing a concealed firearm or a firearm in a car without a license to carry) and § 6108 (possessing a firearm on the streets of Philadelphia). Further, § 6110.2 has recklessness as its mens rea, making it easier for prosecutors to prove as this is a lesser mens rea than other offenses (i.e. specific intent, where a defendant specifically intended to commit a particular crime) and thus easier for the Commonwealth to prove. So, typically, § 6110.2 can be difficult to defend if a defendant is not successful at the suppression hearing.
The Superior Court Restricts § 6110.2
The issue in Ford was whether possessing a firearm with the serial number that had merely corroded would be sufficient for a conviction under § 6110.2. The Superior Court concluded that it would not. In making its decision, the Superior Court employed statutory interpretation to determine what the General Assembly intended when it passed § 6110.2. As previously stated, it is illegal to possess a firearm when the manufacturer’s number is either altered, changed, removed or obliterated. Throughout Ford, the Superior Court emphasized that it would not “add” to § 6110.2, by quoting Commonwealth v. Johnson, 26 A.3d 1078, 1090 (Pa. 2011) holding that “although one is admonished to listen attentively to what a statute says; one must also listen attentively to what it does not say.”
The Superior Court began its analysis by consulting the Crimes Code. § 6102 is the definitions section of the VUFA statutes, however “altered,” “changed,” “removed” or “obliterated” are not defined in this section. The Superior Court then turned to Webster’s Dictionary for guidance. They summarized their findings as follows:
[W]e consult[ed] the dictionary, which defines (1) “alter” as “to cause to become different in some particular characteristic (as measure, dimension, course, arrangement, or inclination) without changing it into something else,” (2) “change” as “to make different . . . in some particular but short of conversion into something else . . . [or] to make over to a radically different form, composition, state, or disposition,”; (3) “remove” means “to get rid of as by moving” as in eradicate or eliminate, and is synonymous with erase; and (4) “obliterate” as “1 : to remove from significance and bring to nothingness : as a: to make undecipherable or imperceptible by obscuring, covering, or wearing or chipping away . . . b: to remove utterly from recognition . . . or c (1): to remove from existence : make nonexistent : destroy utterly all traces, indications, significance of . . . (2) to cause to disappear[.]”
Based on this analysis, the Superior Court held that natural corrosion did not fall within the definitions of altered, changed, removed, or obliterated. Therefore, the defendant should not have been found guilty of § 6110.2. Because the defendant’s conviction for § 6110.2 ran concurrent to his § 6105 conviction and was identical to it, the Superior Court then vacated the defendant’s sentence for § 6110.2, but did not remand it for resentencing.
VUFA Cases and Weapons Offenses
Goldstein Mehta LLC Philadelphia Criminal Defense Lawyers
If you are charged with a VUFA offense, you need an attorney who has the knowledge and expertise to fight your case. Our award-winning Philadelphia criminal defense lawyers have successfully fought countless cases at trial and on appeal. We offer a 15-minute criminal defense strategy session to any potential client. Call 267-225-2545 to discuss your case with an experienced and understanding criminal defense attorney today.
Recent Case Results - Motion to Suppress and Speedy Trial Motions Granted
Award-Winning Philadelphia Criminal Defense Lawyers
The Philadelphia criminal defense attorneys of Goldstein Mehta LLC continue to obtain outstanding results both in and out of the court room. Our defense lawyers have fought for successful outcomes in cases involving a wide variety of charges including robbery, burglary, assault, probation violations and probation detainers, and gun charges. Some of our recent success stories include:
Commonwealth v. G. – Motion to Suppress Confession for Lack of Miranda Warnings Granted in Shooting Case
Criminal Defense Lawyer Zak T. Goldstein, Esq.
In Commonwealth v. G., Attorney Goldstein successfully moved for the suppression of an incriminating statement in a case in which the defendant was charged with gun charges including Violations of the Uniform Firearms Act (“VUFA”) Sections 6108, 6106, and 6105 as well as conspiracy, tampering with evidence, and recklessly endangering another person. The Commonwealth alleged that G. accompanied his co-defendants to a location where a shooting broke out. After the complainants returned fire and shot one of the co-defendants, G. allegedly took the gun and hid it. When G. went to visit his friend at the hospital, police arrested him and began interrogating him, resulting in a confession which implicated G. in hiding the gun.
Attorney Goldstein moved to suppress the statement and the firearm due to violations of the Miranda rule. Pennsylvania and federal law both require the police to read suspects their Miranda warnings prior to interrogating them. Prior to asking any questions which could lead to incriminating answers, police must advise a suspect who has been arrested and taken into custody that the suspect has:
The right to remain silent,
The right to an attorney and that the attorney will be paid for by the government if the suspect cannot afford an attorney, and
That anything the suspect says can be used against them in court.
Shortly before trial, prosecutors admitted that detectives had actually interrogated G. twice. First, they interrogated him immediately upon his arrival at the police station when they had not yet provided him with Miranda warnings at that time. After obtaining a confession, police quickly provided G. with Miranda warnings, questioned him again, and obtained a signed statement.
Attorney Goldstein successfully moved to have both statements suppressed due to detective’s failure to provide Miranda warnings prior to the first interrogation. Under federal law, police may not intentionally fail to provide Miranda warnings in order to obtain a confession, then provide warnings, and quickly re-interrogate the defendant after providing the warnings. Instead, federal courts have applied a sort of “good faith exception” when evaluating whether prosecutors may use a second, Mirandized statement which is substantially similar to a prior un-Mirandized statement. Where police make a mistake in failing to provide Miranda warnings or where the circumstances change enough so that the second statement is not directly related to the first, the statement may become admissible. The Commonwealth attempted to justify the failure to warn by arguing that it had been inadvertent and that there was a break in the chain between the first and second interrogations due to the passage of time.
Here, Attorney Goldstein successfully argued that the police intentionally failed to provide Miranda warnings during the first statement. Additionally, there was no break in the chain between the two interrogations. The second interrogation happened almost immediately, took place in the same location, and involved the same police detective. The trial court agreed and granted the Motion to Suppress, ruling that both statements could not be used at trial. Once the statements were excluded, the Commonwealth agreed that it would not appeal the court’s ruling if G. accepted a plea deal for a misdemeanor charge and probation. The successful Motion to Suppress helped G. avoid a felony gun conviction and years in state prison.
Commonwealth v. A. – Robbery, Burglary, and Assault Charges Dismissed for Speedy Trial Violation.
In Commonwealth v. A., Attorney Goldstein successfully moved to have all charges against the client dismissed due to the prosecution’s violation of Pennsylvania Speedy Trial Rules, specifiically Pennsylvania Rule of Criminal Procedure 600(A). A. and a co-defendant were charged with dressing up as police officers and forcing their way into a massage parlor. Once inside, the defendants allegedly demanded money from the employees. The employees called the police, and the defendants were arrested inside the massage parlor. The Commonwealth immediately brought charges for robbery, burglary, assault, and other related charges.
Unfortunately for the prosecution, the Commonwealth brought the charges without completing its investigation. At the first trial listing, the Commonwealth was not prepared to proceed because it had improperly failed to turn over critical witness statements and evidence in advance of trial. The trial court marked the continuance as a Commonwealth continuance request, and by the time the second jury trial listing arrived, the defendant had been awaiting trial for two years.
Philadelphia Criminal Lawyer Zak T. Goldstein, Esq.
Pennsylvania Rule of Criminal Procedure 600(A) requires that all criminal defendants be brought to trial within 365 days of the filing of the criminal Complaint. There are exceptions for things like court continuances and circumstances outside of the prosecution’s control, but in order to qualify for an exception, the Commonwealth must show that its prosecutors acted with due diligence in prosecuting the case. In this case, Attorney Goldstein successfully argued that the judge at the first trial listing had already found that the prosecution acted without due diligence in failing to provide witness statements and other discovery materials in advance of the first trial date. Because the Commonwealth never asked the first judge to reconsider the ruling in writing, Rule 600 barred the Commonwealth from asking the new trial judge to reconsider the first judge’s ruling without some showing of obvious error on the part of the first judge. The court agreed and dismissed all of the charges in this extremely serious case.
Commonwealth v. M. – Car Theft Charges Dismissed at Preliminary Hearing
In Commonwealth v. M., the client was charged with multiple counts of Receiving Stolen Property, Theft by Unlawful Taking, Unauthorized Use of an Automobile, and Theft from a Motor Vehicle. Prosecutors alleged that in one case, M. stole the complainant’s car and drove it around for a night before leaving it abandoned on a nearby street. Further, numerous valuable items were missing from the car, leading to additional allegations that M. had stolen the items.
In a second case which had been joined for the preliminary hearing, prosecutors alleged that M. broke into a parked car, stole valuable items, and transported those items to his house. When prosecutors executed a search warrant on M.'s house, they found M. and another gentleman in the living room along with the stolen items. Neither man was closer to the items, said anything incriminating, or attempted to flee, and the other man's hospital ID had actually been found by police in the stolen car in the first case.
In both cases, the prosecution attempted to rely entirely on hearsay at the preliminary hearing under the Superior Court's opinion in Commonwealth v. Ricker. The prosecution sought to have a police detective, who had no personal knowledge of who took the car or took items from the other car, testify that a witness who failed to appear for court saw M. driving the car on the night in question.
Attorney Goldstein’s repeated objections to this hearsay testimony led to it being excluded from evidence at the preliminary hearing, and without the hearsay, the evidence was completely insufficient for the preliminary hearing judge to hold M. for court. This was particularly true in light of the fact that the other gentleman's hospital wristband was found by police in the stolen car. Accordingly, the court dismissed all charges against M. This case shows that even with the trend of judges permitting more and more hearsay at preliminary hearings, there are still limits. This is especially true in Philadelphia where judges tend to require that witnesses have some level of personal knowledge before they will hold a case for court.
Probation Detainers Lifted – In the last six weeks, our Philadelphia criminal defense attorneys have successfully moved to have probation detainers lifted for three separate clients who were on probation and subsequently arrested on new charges. This includes the lifting of a probation detainer for a client who was on probation for a gun charge and who was arrested on a new case of Possession with the Intent to Deliver.
State v. D. – Prosecution Agrees to Dismiss All Charges in New Jersey Prison Contraband Case
In State v. D., the client was charged with third degree indictable offenses in New Jersey for allegedly smuggling drugs into the prison during a visit with a friend. The prosecution obtained both video of the incident and phone calls which it claimed implicated D. in the offense. After convincing the Assistant Prosecutor that even if real, the phone calls would not be admissible against D. due to violations of New Jersey wiretap and recording laws, the prosecution agreed to dismiss all charges. D. will avoid a felony conviction and jail time.
Commonwealth v. K. – All Charges Dismissed in Third Strike Carjacking (Robbery of a Motor Vehicle) Case.
K. was charged with stealing his ex-girlfriend’s car by snatching the keys out of her hand and driving off in the car. Although this allegation would only have been Robbery as a felony of the second degree, the case became a third strike and a carjacking because of the fact that K. allegedly took a car. Carjacking (Robbery of a Motor Vehicle) is considered a crime of violence under Pennsylvania law for purposes of the three strikes rule. Due to prior convictions, K. would have faced a mandatory 25-50 years in prison if convicted of Robbery of a Motor Vehicle because carjacking is a “strike” case. Fortunately, our criminal defense attorneys were able to have all charges dismissed at the preliminary hearing level.
Commonwealth v. J. – Our criminal defense lawyers were able to successfully negotiate a misdemeanor offer of probation for a client who was initially charged with F1 Strangulation, Robbery, and Aggravated Assault. First, we were able to have the strangulation charge dismissed at the preliminary hearing and the other felonies graded as felonies of the second degree. Once the felonies were no longer F1 strike offenses, the Commonwealth’s offer substantially improved, and we were eventually able to negotiate a misdemeanor probationary offer for the client, thereby avoiding jail time and a felony conviction.
Criminal Defense Attorney Demetra P. Mehta, Esq.
Commonwealth v. A. – All charges against A. were dismissed after our defense lawyers negotiated for A. to participate in the domestic violence diversionary program. After A. completed community service, counseling, and paid a small fine, the Commonwealth withdrew Simple Assault, Terroristic Threats, and Recklessly Endangering Another Person charges against A.
Commonwealth v. R. - The client was arrested and charged with Robbery, Assault, and related charges while on probation for a serious offense. Because there was clear video of the incident occurring, the client was hoping to obtain a plea deal for the shortest possible sentence. The client's previous attorney had been unable to negotiate for anything less than a 1-2 year state prison sentence. After retaining Goldstein Mehta LLC, our defense lawyers were able to negotiate a sentence of 11.5 - 23 months with work release eligibility and no additional jail time on the direct probation violation.
Charged with a crime? Speak with a Philadelphia Criminal Defense Lawyer Today
Goldstein Mehta LLC Philadelphia Criminal Defense Lawyers
If you are facing criminal charges or are interested in appealing a conviction, we can help. Our award-winning Philadelphia criminal defense lawyers have successfully resolved countless cases at trial and on appeal. We offer a 15-minute criminal defense strategy session to any potential client. Call 267-225-2545 to discuss your case with an experienced and understanding criminal defense attorney today.
PA Superior Court Rejects Good Faith Exception to Exclusionary Rule in Birchfield Cases
Commonwealth v. Carper
The Pennsylvania Superior Court has decided the case of Commonwealth v. Carper. In Carper, the Court held that prosecutors may not introduce illegally obtained blood test results in Driving Under the Influence (“DUI”) cases despite the fact that the police relied on then-settled law which permitted warrantless blood testing of DUI suspects. The Superior Court specifically rejected the application of the “good faith exception” and held that the evidence remains inadmissible despite the fact that the police officers may have acted in good faith and not realized that they were violating the law.
Carper involved a relatively straight-forward DUI case. A Pennsylvania State Police Trooper pulled Carper over in October 2014 for an expired inspection sticker. During the ensuing stop, the Trooper began to suspect Carper of driving under the influence of a controlled substance. The Trooper arrested Carper, transported him to the hospital, and informed him that if he did not consent to a blood draw, he would face increased criminal penalties. Carper agreed to the blood draw, and the blood draw showed the presence of a controlled substance.
Motion to Suppress
Carper moved to suppress the evidence under the Fourth Amendment of the United States Constitution. Notably, Carper did not move to suppress the blood results under the Pennsylvania Constitution. The trial court held a suppression hearing, and the Commonwealth introduced evidence in an attempt to show that it complied with both the Fourth Amendment of the United States Constitution and Article I Section 8 of the Pennsylvania Constitution. Following the hearing, the United States Supreme Court decided Birchfield v. North Dakota, and then Carper filed a post-suppression hearing brief in which he also argued that the blood results should be suppressed under the Pennsylvania Constitution. Likewise, the Commonwealth filed a brief in which it argued that the Pennsylvania Constitution did not bar the introduction of the blood results into evidence.
Birchfield v. North Dakota made it illegal for states to impose criminal penalties on DUI suspects who refuse a warrantless blood draw. Thus, the trial court granted the Motion to suppress, agreeing with the defense that the police illegally coerced the defendant into consenting to the blood draw by informing the defendant that he would face more severe criminal penalties if he refused chemical testing.
The Good Faith Exception to the Exclusionary Rule
The Commonwealth appealed. In its appeal, the Commonwealth argued for the application of the good faith exception to the Exclusionary Rule. In the federal system, prosecutors may still use unlawfully seized evidence if police acted in good faith when they obtained the evidence. For example, courts have found that officers acted in good faith where they arrested a defendant on what they believed to be a valid warrant despite the fact that the warrant had actually been lifted. Likewise, federal courts have held that police act in good faith when they rely on existing case law when conducting a search even if later case law subsequently changes the legality of the search. Thus, the Commonwealth asked the Superior Court to find that the good faith exception applies in Birchfield cases because police relied on well-established case law. The Commonwealth also argued that the defendant failed to properly preserve his state law challenge to the blood draw because defense counsel moved to suppress the evidence only under the United States Constitution prior to the hearing and never mentioned the state law claim until the defense filed its post-hearing brief.
The Superior Court rejected both of the Commonwealth’s arguments. First, the Court recognized that Pennsylvania appellate courts have repeatedly found that there is no good faith exception to the exclusionary rule in Pennsylvania. Thus, while the good faith exception may apply in federal court, it does not apply in Pennsylvania state courts. The only issue is whether officers violated the law; it does not save the Commonwealth’s case that the officers relied on the law at the time. Second, the Court rejected the Commonwealth’s argument that Carper waived the state law claims by failing to mention them in the initial motion. This would have led to the motion being denied because under the federal law claims, the good faith exception would have applied. Nonetheless, the Court rejected this argument as well, finding that the Commonwealth had not been prejudiced because the Commonwealth extensively briefed the state law issues and presented testimony relating to the issue of coercion at the suppression hearing. Further, the defense preserved the issue by filing the post-hearing brief and allowing the trial court to rule on it. Therefore, the Court rejected both of the Commonwealth’s appellate issues.
Following Carper, it is clear that the good faith exception does not apply in Birchfield DUI cases. States may not penalize DUI suspects for refusing to submit to blood testing without a search warrant. Although prosecutors continuously ask the appellate courts to adopt a good faith exception in Pennsylvania, the courts have fortunately refused to do so thus far.
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Philadelphia Criminal Defense Attorneys
If you are facing DUI charges or fighting any other criminal case, we can help. Our award-winning criminal defense attorneys have successfully represented thousands of clients in all types of criminal cases. Don't just assume you have to plead guilty and are going to lose your license. Call 267-225-2545 for a free 15-minute criminal defense strategy session with one of our Philadelphia DUI Defense Attorneys and Criminal Lawyers.
United States Supreme Court To Review Whether Police Need Warrant To Obtain Cell Phone Location Data
Potentially recognizing that the frame work for when police and federal agents are required to seek a search warrant to obtain digital information has become outdated, the United States Supreme Court announced that it will review whether the police are required to get a search warrant in order to obtain a suspect’s cell phone records. Local and federal law enforcement routinely seek cell phone location data from a suspect’s telephone company in order to track the suspect’s whereabouts around the time of the crime. The location data can be extremely powerful as circumstantial evidence in cases where the cell phone data puts the suspect at or near the scene of the crime at the time of its commission. For example, if police believe that the suspect committed a homicide, they could use cell phone location data to show that the suspect was near the decedent at the time of the murder.
Current Standards for Obtaining Cell Phone Location Data
Under existing state and federal law, police officers are generally not required to obtain a search warrant in order to retrieve this information from a phone company. Instead, in many jurisdictions, law enforcement officers simply submit a request to the phone company, and the phone company will provide the information without a warrant and court order. In other jurisdictions, officers may be required to obtain a court order in order to retrieve the data, but the court orders may be issued on a standard of evidence lower than the probable cause standard required in order to obtain an actual search warrant. This is the case in federal court, where prosecutors must show only that there are “reasonable grounds” for the records and that they are “relevant and material” to an investigation.
Courts have traditionally allowed police to dispense with the warrant requirement in obtaining this type of data because the data is not stored in the suspect’s phone or on the suspect’s person. Instead, the defendant necessarily shared the data with a third-party, the phone company, by using the phone. Thus, courts have held that defendants do not have a reasonable expectation of privacy in information that they have publicly shared or shared with third parties, and courts have not needed to obtain search warrants in order to obtain that type of information.
Reasonable Expectation of Privacy in Cell Phone Data
As a general rule, defendants may move to suppress the results of a search only where they had a reasonable expectation of privacy in the place searched. Obviously, you have a reasonable expectation of privacy in your home, car, and pockets, but courts have rejected the idea that a criminal defendant has a reasonable expectation of privacy in something that he or she has shared with a third party. This rule may have made sense twenty years ago before the advent of technology which literally tracks a person’s every movement. Devices like cell phones, sports watches, and GPS systems all track a person’s whereabouts at all times, making it much more difficult for the government to argue that a suspect should not have a privacy interest in the resulting data. If the government is not required to obtain a search warrant, then the government can essentially obtain all of the details of a person’s life without even having probable cause.
After recently determining that police must have a search warrant in order to search the contents of an arrestee’s search warrant, this case suggests that the High Court may be prepared to re-think the reasonable expectation of privacy doctrine given the realities of modern technology. The case on appeal is Carpenter v. United States. In Carpenter, without getting a search warrant which would have required probable cause, FBI agents obtained cell phone records for the defendant from his phone company which covered 127 days and revealed 12,898 separate points of location data. The data ultimately connected Carpenter to a string of cell phone store robberies, and Carpenter was convicted at trial. On appeal, the Sixth Circuit Court of Appeals ruled 2-1 that the Fourth Amendment does not require law enforcement to obtain a search warrant prior to seeking this type of data. Carpenter has appealed to the United States Supreme Court, and the Court will review whether the police should be required to obtain a search warrant in order to get this highly personal data. Search warrants are not particularly difficult for the government to obtain, and a decision in favor of Carpenter would limit the government’s ability to track your every movement without at least some showing of probable cause.
Award-Winning Philadelphia Criminal Defense Lawyers
Philadelphia Criminal Lawyers Demetra Mehta and Zak T. Goldstein
If you are facing criminal charges, we can help. Our Philadelphia criminal defense lawyers have successfully defended thousands of clients against a wide variety of criminal charges in preliminary hearings and at trial. Call 267-225-2545 for a complimentary 15-minute criminal defense strategy session with one of our award-winning defense attorneys.
Read the Sixth Circuit’s Opinion: https://scholar.google.com/scholar_case?case=14626167511079628834