Philadelphia Criminal Defense Blog

Zak Goldstein 7/30/19 Zak Goldstein 7/30/19

PA Superior Court: Sentencing Gradation of Unlawful Contact with Minor Charge Must Take Acquittal on More Serious Charges Into Account

Philadelphia Criminal Defense Lawyer Zak Goldstein

The Pennsylvania Superior Court has decided the case of Commonwealth v. Pope, holding that the gradation of an unlawful contact with minor charge must take an acquittal on more serious charges into account. This is because the unlawful contact with a minor provides that unlawful contact shall either be graded as a felony of the third degree or the same as the most serious sexual offense that the defendant is alleged to have committed. In this case, the defendant was acquitted of first-degree-felony Attempted Involuntary Deviate Sexual Contact, and therefore the trial court erred in grading the unlawful contact with a minor charge as a felony of the first degree at sentencing.

The Facts of Pope

In Pope, the Commonwealth alleged that the minor complainant lived with her mother and her mother’s boyfriend, the defendant, from the age of three years old until she turned thirteen. At some point, the complainant began dating someone her own age. The complainant accused the defendant of extorting her for sexual favors in exchange for permission to visit her boyfriend. Specifically, she testified that she had to give the defendant a hand job for a two hour visit, two hand jobs for a four hour visit, or a blow job for a full day visit with her boyfriend. She testified that this happened on numerous occasions. She also claimed that on one occasion, the defendant attempted to have anal sex with her.

The complainant eventually told a friend that this had been happening, and her father eventually learned of the allegations. Her father took her to the police station to make a report. Police eventually charged the defendant with attempted involuntary deviate sexual intercourse (“IDSI”), aggravated indecent assault, indecent assault, one count of unlawful contact with a minor, and one count of corruption with minors. Following a jury trial, the defendant was convicted of unlawful contact with a minor and corruption of minors. The jury acquitted him of the other offenses. At sentencing, the trial court graded the unlawful contact with minors charge as a felony of the first degree and sentenced the defendant to 62-124 months’ incarceration. The defendant appealed, and the Superior Court denied the appeal.

PCRA Challenge to the Illegal Sentence

After the Superior Court denied the appeal, the defendant filed a timely Post-Conviction Relief Act Petition, eventually alleging, among other things, that his trial and appellate attorneys provided the ineffective assistance of counsel in failing to challenge the F1 gradation of the unlawful contact with minors charge. The trial court dismissed the petition, and the defendant appealed the denial of the PCRA to the Pennsylvania Superior Court. This time, the Superior Court granted relief.

The Superior Court Appeal

Initially, the defendant claimed that he had received the ineffective assistance of counsel because his prior attorneys failed to challenge the gradation of the unlawful contact charge. The Superior Court, however, concluded that it had the power to correct an illegal sentence even on the direct appeal of a timely PCRA Petition and that it did not have to reach the issue of whether the prior attorneys were ineffective. Instead, the Superior Court simply agreed with the defendant.

Section 6318 of the Pennsylvania Crimes Code defines unlawful contact with a minor as follows:

(a) Offense defined.--A person commits an offense if he is intentionally in contact with a minor, or a law enforcement officer acting in the performance of his duties who has assumed the identity of a minor, for the purpose of engaging in an activity prohibited under any of the following, and either the person initiating the contact or the person being contacted is within this Commonwealth:

(1) Any of the offenses enumerated in Chapter 31 (relating to sexual offenses).

(2) Open lewdness as defined in section 5901 (relating to open lewdness).

(3) Prostitution as defined in section 5902 (relating to prostitution and related offenses).

(4) Obscene and other sexual materials and performances as defined in section 5903 (relating to obscene and other sexual materials and performances).

(5) Sexual abuse of children as defined in section 6312 (relating to sexual abuse of children).

(6) Sexual exploitation of children as defined in section 6320 (relating to sexual exploitation of children).

(b) Grading.--A violation of subsection (a) is:

(1) an offense of the same grade and degree as the most serious underlying offense in subsection (a) for which the defendant contacted the minor; or

(2) a felony of the third degree; whichever is greater.

Thus, the key issue in the appeal was what the most serious underlying offense in subsection (a) for which the defendant contacted the minor would be following the jury’s acquittal on the most serious charge of IDSI. In general, the Commonwealth does not even have to charge a defendant with other offenses in order to pursue a prosecution for unlawful contact. Instead, the Commonwealth would simply allege unlawful contact with a minor, and if the prosecution could prove that the contact was for the purpose of committing IDSI (for example by obtaining oral or anal sex), then the unlawful contact would be properly graded as an F1.

The analysis changes, however, when a jury acquits the defendant of specific charges. Where the jury acquits the defendant of more serious charges, the sentencing court is not permitted to guess which offense the defendant sought to commit when he contacted the minor. Instead, the sentencing court should apply the default gradation of a felony of the third degree. Further, the jury instructions did not provide any clarification in this case as to which offense the jury found the defendant had attempted to commit. Therefore, the Superior Court reversed the sentence and found that the defendant should have been sentenced on unlawful contact with a minor as a felony of the third degree. The defendant will receive a new sentence, and it will necessarily be shorter because the maximum sentence for a felony of the third degree is 3.5-7 years’ incarceration.

FACING CRIMINAL CHARGES? WE CAN HELP.

Criminal Defense Lawyers Demetra Mehta and Zak Goldstein

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, Rape, and 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 6/28/19 Zak Goldstein 6/28/19

PA Supreme Court: 4th Amendment Does Not Bar Computer Repair Technicians From Showing Police Your Illegal Files

The Pennsylvania Supreme Court has decided the case of Commonwealth v. Shaffer. The Court held that the Fourth Amendment does not prevent computer repair technicians who find child pornography on a computer brought in for repair from showing that illegal material to the police. The Constitution also does not prohibit the police from looking at what the repair technicians found without a search warrant so long as the police do not attempt to view additional files and portions of the hard drive until they have obtained a search warrant. The Supreme Court reaffirmed its prior holdings that the Fourth Amendment only provides protection against governmental action. However, the Court did hold that individuals maintain privacy interests in their computer files even when they are turned over to a private commercial establishment.

Commonwealth v. Shaffer

The defendant brought his laptop computer to a computer repair shop called CompuGig. In order to obtain repair services, the defendant was required to complete CompuGig’s intake form which asked what problems the customer was experiencing. This form listed several options. The defendant marked the boxes indicating “Spyware/virus” and “Can’t get to Internet.” He also provided his login password and told the employee that his son downloaded some things and now there were a lot of pop-ups and that the internet had stopped working.

After conducting a diagnostic testing, one of CompuGig’s technicians believed that the defendant’s computer had a failing hard drive. The technician called the defendant and asked if he would consent to replacing the hard drive. The defendant consented. The technician also took an image of the hard drive so that he could transfer it to the defendant’s new hard drive. However, the technician was having difficulty transferring the files on the defendant’s old hard drive to his new one. The technician began to manually open the files on the hard drive and copy them. While doing this, the technician uncovered what he believed to be sexually explicit photos of children. It is important to note that the technician was not searching for this material and had never been asked by law enforcement to look for evidence of child pornography. After discovering this contraband, the technician notified his boss, and the store called the police.

Later that afternoon, Officer Maloney of the Cranberry Township Police Department arrived at CompuGig. The store owners advised Officer Maloney that the technicians found explicit images of young girls on the defendant’s laptop and took the officer to the room where the technician had been working on the computer. Officer Maloney then asked to see the images that the technician had found. The technician, using the “exact route taken to find the images” which he had used earlier, showed Officer Maloney the pictures. After viewing these images, Officer Maloney directed the technician to “shut down the file,” and he seized the laptop, external hard drive copy, and power cord.

Detective Irvin of the Cranberry Township Police Department went to the defendant’s home and questioned him. The defendant admitted to having some images on his computer depicting children as young as eight years old in sexually explicit positions. He also identified the folders where these images were stored. Detective Irvin met with the defendant again and obtained a written inculpatory statement regarding the pictures on his computer.

Prosecutors charged the defendant with possession of child pornography and criminal use of a communication facility. The defendant then filed a pretrial omnibus motion to suppress the contraband images discovered on the hard drive of his laptop computer.

Can Police Search Your Computer Without A Warrant If The Store Found the Illegal Images First?

In his Motion to Suppress, the defendant argued that the police illegally searched his computer when Officer Maloney directed the technician to open the defendant’s computer files and display the suspected contraband images and then subsequently seized the laptop and the copy of the external hard drive. Further, he argued that the police conduct constituted a warrantless search of his laptop in violation of his reasonable expectation of privacy, as well as a trespass upon his property in violation of both the Pennsylvania and United States Constitutions. He also argued that his statements that he made to the detective were the fruit of the poisonous tree and should also be suppressed.

In response, the Commonwealth argued that the defendant abandoned his expectation of privacy in the computer files stored on the laptop. Notably, the Commonwealth did not argue the private search doctrine. Instead, the Commonwealth focused primarily on the Pennsylvania Superior Court’s decision in Commonwealth v. Sodomsky. The facts of Sodomsky were very similar to those in the defendant’s case. In Sodomsky, the Superior Court held that the defendant in that case had no reasonable expectation of privacy in his illegal computer files. The Sodomsky Court held that individuals do maintain a privacy interest in some things that are accessible to the public and thus can be constitutionally protected. Therefore, it is a very fact specific inquiry to determine whether a defendant abandoned his privacy interest. In Sodomsky, the Superior Court held that the defendant abandoned his interest because the computer employees informed him that the operability of his computer would be tested and that he did not inquire as to the manner of testing or restrict the employee’s access to the location of the illicit files. They also emphasized that the defendant did not delete the photos from his computer even though he turned it over to the police.

The trial court denied the defendant’s motion to suppress. The trial court held that the defendant abandoned his expectation of privacy when he requested repairs on his computer related to complaints of a virus and an inability to use the Internet and consented to the replacement of his hard drive. The trial court also rejected the defendant’s trespass argument because the technician was engaged in conduct permitted by the defendant when the files were discovered and thus there was no trespass on the defendant’s effects. The defendant then proceeded by way of a bench trial where he was found guilty. He was sentenced to six to twelve months of incarceration, followed by 156 months of probation. The defendant then filed a timely appeal.

The Superior Court’s Decision

The Superior Court affirmed the trial court’s decision. The Superior Court focused primarily on the Sodomsky decision. The defendant filed an appeal to the Pennsylvania Supreme Court and the Court granted his petition for allowance of appeal to determine whether the defendant abandoned his expectation of privacy in in the computer.

What is the Private Search Doctrine?

The Fourth Amendment applies only to the government. Thus, a criminal defendant cannot successfully argue that a private citizen, while acting in a purely private capacity, violated his or her constitutional rights when that person conducted a search and seizure of a defendant’s property. The United States Supreme Court has held that the Fourth Amendment is only implicated “if the authorities use information with respect to which the expectation of privacy has not already been frustrated.” In other words, if a private party searches a defendant’s property, and the government does not exceed the private party’s search, then a defendant cannot claim that their Fourth Amendment rights were violated. Pennsylvania also follows the Private Search Doctrine as discussed in Commonwealth v. Corley.

The Pennsylvania Supreme Court’s Decision

The Pennsylvania Supreme Court affirmed the trial court’s denial of the defendant’s motion to suppress. As a preliminary matter, the Pennsylvania Supreme Court held that defendants maintain privacy interests in their computer files even when turned over to a private company. However, the Pennsylvania Supreme Court held that even though the defendant maintained a privacy interest in the files, because a non-governmental actor discovered them, the Fourth Amendment could not provide relief to him.

The Commonwealth had not not argued the Private Search Doctrine at the motion to suppress, but the Pennsylvania Supreme Court held that it could still apply the doctrine to the defendant’s case. In the defendant’s case, the Court found it of no consequence that Officer Maloney asked the technician to show him the illicit files because the technician had already discovered them. Therefore, the defendant’s privacy interest in them had already been compromised. As such, he was not entitled to relief, and consequently the defendant will not get a new trial.

Facing criminal charges? We can help.

Philadelphia Criminal Defense Attorneys Demetra Mehta and Zak Goldstein

Zak Goldstein 6/11/19 Zak Goldstein 6/11/19

PA Superior Court: Defendant Entitled to Less Stringent SORNA Registration Requirements Where Jury Did Not Find Specific Date of Offense

Philadelphia Criminal Defense Lawyer Zak T. Goldstein, Esq.

The Pennsylvania Superior Court has decided the case Commonwealth v. Alston. This decision reaffirms previous decisions that held that Sexually Violent Predator hearings under the original Sex Offender Registration and Notification Act (“SORNA”) are unconstitutional. Further, in this case, the Superior Court ruled that where the defendant’s crimes could have occurred both before and after the enactment of SORNA and the jury has not made a specific determination as to the date of the offense, the defendant should be required to register under the less onerous version of the statute.

Commonwealth v. Alston

The defendant was accused of sexually assaulting the complainant from May 28, 2009 to May 1, 2013. The complainant was eleven years old when the abuse began. The complainant’s sister eventually discovered the abuse and notified the police. After a three-day jury trial that began on February 10, 2016, the defendant was found guilty of a multitude of charges including: statutory sexual assault, rape, involuntary deviate sexual intercourse (“IDSI”), indecent assault, criminal use of a communication facility, unlawful contact with a minor and corruption of minors. Significantly, the jury did not specifically determine the dates on which the defendant committed these offenses.

The trial court sentenced the defendant to an aggregate term of 15 to 40 years’ incarceration. Additionally, because rape of a child and IDSI with a person less than 16 years old are both Tier III offenses under SORNA, the defendant was required to register as a sex offender for the rest of his life. The trial court also held a Sexually Violent Predator hearing and determined that the defendant was in fact a Sexually Violent Predator and therefore subject to lifetime reporting requirements.

The defendant eventually appealed, and on appeal he raised one issue: whether the trial court improperly imposed a lifetime reporting requirement under the original SORNA statute following the SVP hearing?

What is an SVP?

A SVP is a sex offender who is deemed to have a mental abnormality or personality disorder that makes the person likely to engage in predatory sexually violent offenses. After someone is convicted of sexually violent offense in Pennsylvania, the court can order a SVP assessment to be conducted by the Sex Offender Assessment Board “SOAB”). The SOAB publishes its findings to the parties, and the court will then hold a hearing to determine whether the person is an SVP. It is noteworthy that the standard proof for these hearings is not beyond a reasonable doubt (the standard for criminal trials). Instead, it is the clear and convincing evidence standard, which is a much lower standard. The original SORNA statute allowed the judge to make the SVP determination instead of a jury, and the amended SORNA statute retains this defect.

What Happens if You Are Classified as an SVP?

If someone is deemed an SVP, the person is required to register with the Pennsylvania State Police for the rest of their life. Additionally, the individual is required to participate in monthly (at a minimum) sex offender counseling from a provider that is approved by the SOAB. Also, the local authorities will notify the community and provide the SVP’s name and address. This means that someone who was convicted of a Tier I Offense which may only require 15 years of registration could be required to register for life if they are found to be a Sexually Violent Predator.

Why Were SVP Hearings Ruled Unconstitutional?

In Commonwealth v. Butler, the Pennsylvania Superior Court held that SVP hearings as provided for by SORNA are unconstitutional because they expose defendants to an enhanced criminal penalty without any requirement that the jury make the necessary findings beyond a reasonable doubt. Because the SVP procedures permitted the trial judge to make the ruling instead of a jury and because they used a lesser standard, the Butler Court found that the procedures were unconstitutional. The Butler Court held that the trial courts can no longer designate convicted defendants as Sexually Violent Predators or hold SVP hearings “until the General Assembly enacts a constitutional designation mechanism.”

Is There a New Version of SORNA?

Yes. In February of 2018, Governor Tom Wolf signed into law Act 10. Act 10 amended several provisions of SORNA and added new sections. Notably, Act 10’s Subchapters H and I addressed reporting requirements for sex offenders that committed their crimes on or after April 22, 1996, but before December 20, 2012. Subchapter I has less stringent reporting requirements than Subchapter H. Notably, Act 10 retained the “clear and convincing” standard for SVP hearings and there was not a “constitutional designation mechanism” in the statute either. Challenges to the new statute are ongoing. The Commonwealth and legislature, however, are defending the statute by arguing that because the reporting requirements are somewhat less stringent, the SVP designation no longer constitutes punishment. If it does not constitute criminal punishment, then the facts do not need to be found by a jury using the beyond a reasonable doubt standard. This argument seems unlikely to prevail, but it is always difficult to predict what the courts will do in these cases.

The Pennsylvania Superior Court’s Decision

The Court held that the defendant should not have been deemed an SVP because the procedures for finding that someone is an SVP under the old version of SORNA remain unconstitutional and because the jury did not make a specific finding as to the dates on which the illegal sexual conduct occurred. Because the defendant’s alleged actions could have occurred both before and after SORNA’s effective date and the jury did not make a specific finding, the defendant was entitled to the benefit of the doubt because any ambiguity in criminal law generally must be resolved in favor of the defendant. Therefore, the Court ruled that he should be required to register under the newly-created Subchapter I of the amended SORNA statute. Therefore, the case was remanded to the trial court for the defendant to be advised of his new registration requirements and raise any challenges to those requirements. This opinion did not address the constitutionality of the amended SORNA statute, and that litigation is ongoing at this time.

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 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 5/6/19 Zak Goldstein 5/6/19

PA Superior Court: Relevant, Exculpatory DNA Evidence Requires New Homicide Degree of Guilt Hearing

The Pennsylvania Superior Court has decided the case of Commonwealth v. Payne. The Superior Court held that the trial court erred in denying the defendant a new degree of guilt hearing where recently-obtained DNA evidence showed that the defendant did not rape the victim in a case in which the prosecution obtained a conviction for first degree murder by relying primarily on the fact that the defendant had allegedly raped the victim prior to killing her. This case involved a Post-Conviction Relief Act (“PCRA”) challenge based on after-discovered evidence to the defendant’s conviction for first degree murder at a degree of guilt hearing in which the defendant pleaded guilty to homicide generally but argued that he should only be convicted of third degree murder. The degree of guilt matters tremendously in a homicide case because first degree murder requires a sentence of life without parole and third degree murder does not.

Commonwealth v. Payne

In 1977, the defendant pled guilty to murder generally, and three judges were empaneled to decide his degree of guilt. At this hearing, the Commonwealth presented evidence to support its position that the defendant committed a first degree murder. Specifically, the Commonwealth argued that the defendant murdered the victim while he was raping her.

As part of its case-in-chief, the Commonwealth presented the testimony of a Mr. Evans who was incarcerated with the defendant in Erie County prison. Mr. Evans testified that the defendant admitted to him that he strangled the victim in the woods after he raped her and that her death “was a culmination of a sexual fantasy that he had been living with for a long time; that he likes to tie women up and do crazy things to ‘em.” The Commonwealth also called a chemist employed with the Pennsylvania State Police to corroborate Mr. Evans’s testimony that the victim died while “protesting a sexual attack upon her.” The Commonwealth also presented a statement made by the defendant to the police.

Per the Superior Court’s decision, this statement was similar to Mr. Evans’s testimony. At the conclusion of the hearing, the defendant argued that this was a third degree murder. The Panel rejected his argument and convicted the defendant of first degree Murder. In its decision, the Panel placed significant weight on the conclusion that the defendant raped the victim when making its determination that it was a first degree murder and not third degree. Although other evidence was presented, the Panel relied exclusively of the testimony of Mr. Evans and the chemist in its opinion. The defendant was therefore automatically sentenced to life imprisonment without parole. The defendant then filed the first of several appeals and PCRA petitions.

After several unsuccessful attempts at post-conviction relief, on January 8, 1997, the defendant filed a PCRA petition requesting DNA testing on the seminal fluid that was recovered from the victim’s body. The PCRA court denied his petition. The Pennsylvania Superior Court affirmed the trial court’s decision and the Pennsylvania Supreme Court denied his petition for allowance of appeal. On February 6, 2003, the defendant filed a Motion for DNA testing pursuant to the then-newly passed provision of the PCRA permitting DNA testing under certain circumstances. The PCRA court again denied his motion, and he appealed to the Pennsylvania Superior Court. The Pennsylvania Superior Court affirmed the trial court decision and the Pennsylvania Supreme Court denied his petition for allowance of appeal.

Undeterred, the defendant then filed a complaint in the United States District Court for the Western District of Pennsylvania against the Erie County District Attorney’s Office alleging violations of 42 U.S.C. § 1983 for its refusal to permit the DNA testing. While his case was being litigated in federal court, the defendant filed a second motion for DNA testing. On October 4, 2011, the PCRA court again denied relief and both the Pennsylvania Superior Court and Supreme Court also denied him relief. However, on December 16, 2014, the United States District Court signed a stipulated order permitting the post-conviction DNA testing. The DNA test results established conclusively that the defendant was excluded as a contributor to the seminal fluid found on the victim’s body.

Based on this new evidence, the Defendant filed another PCRA petition asserting that he is entitled to a new trial or degree of guilt hearing based on this after-discovered evidence. Again, the PCRA court denied him relief and the defendant filed another appeal to the Pennsylvania Superior Court.

What is a Degree of Guilt Hearing?

A degree of guilt hearing is required when a defendant pleads generally to murder in a case in which the defendant could receive the death penalty. If a defendant pleads guilty or no-contest, then the degree of guilt shall be determined by a jury, unless the Commonwealth elects to have a judge make a determination as to what degree of murder the defendant is guilty of and consequentially what his sentence will be. These hearings are quasi-trials where the Commonwealth and the defense can present evidence and argue that the defendant should be found guilty of first or third degree murder.

What is after-discovered evidence under the PCRA?

42 Pa. C.S. § 9543 (a)(2)(vi) is the statute that governs the after-discovered evidence prong of the PCRA. In order to obtain relief under this subsection, which could include a new trial and/or sentencing, a defendant must show that 1) the evidence has been discovered after trial and it could not have been obtained at or prior to trial through reasonable diligence; 2) the evidence is not cumulative; 3) it is not being used solely to impeach credibility; and 4) it would likely compel a different verdict. The test is conjunctive, meaning that each element must be satisfied. Further, the defendant must satisfy each element by the preponderance of the evidence standard in order to be successful.

In making this determination, the court will consider several factors in making its decision including: the nature of the new evidence; whether, and to what extent, the new evidence is consistent or inconsistent with the other trial testimony; whether, and to what extent, the new evidence is consistent or inconsistent with documentary evidence; the prosecution’s theory at the original trial, and the difficulty of making this argument in light of the new evidence; the prosecutor’s closing remarks, which may demonstrate the importance of the new evidence; and other relevant factors. However, one must remember that this “after-discovered evidence” does not require that the new evidence prove a defendant’s innocence beyond a reasonable doubt. In other words, the defendant does not have to prove his innocence in order to be successful in his petition, he is only required to show that it would have likely compelled a different outcome.

The Superior Court’s Decision

The Pennsylvania Superior Court held that the defendant was entitled to a new degree of guilt hearing. According to the Superior Court’s decision, the only issue was whether the defendant had established by a preponderance of the evidence that the DNA evidence would have changed the outcome of the trial if it had been introduced. In the instant case, the Superior Court held that this evidence would have changed the outcome of the hearing.

The reason is because the Commonwealth’s theory of the case was that the defendant killed the victim while sexually assaulting her. The prosecution repeatedly emphasized the evidence of seminal fluid during the closing argument to the Panel arguing that “at least it was a rape” and that the presence of seminal fluid was proof of the intent required for a first-degree murder conviction. As such, because the DNA evidence was uncontroverted in that the defendant was not the source, the Panel erred in placing such significant weight on it when making its decision. Further, this evidence discredits Mr. Evans’s testimony, a key witness against the defendant. Therefore, the defendant satisfied the after-discovered evidence requirements and the defendant is entitled to a new degree of guilt hearing.

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 obtained full acquittals, dismissals, and other successful results in cases involving charges such as Conspiracy, Aggravated Assault, Theft, Rape, and 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.