PA Superior Court Finds Sexually Violent Predator Classification Unconstitutional

More Changes for Pennsylvania's Unconstitutional Megan's Law Statute

The Pennsylvania Superior Court has just decided the case of Commonwealth v. Butler, finding that Pennsylvania's system of classifying certain sex offenders as Sexually Violent Predators is unconstitutional. The Court held that that 42 Pa C.S.A. § 9799.24(e)(3), the section of the Sexual Offender Registration and Notification Act (“SORNA) that deals with designating an individual as a Sexually Violent Predators (“SVP”), is unconstitutional. This decision could impact thousands of individuals throughout Pennsylvania. Further, this is yet another case where an appellate court has found a section of the SORNA statute unconstitutional. If you are charged with a SORNA offense, it is imperative that you contact an attorney who is familiar with this rapidly evolving area of law.

Commonwealth v. Butler 

In Butler, the defendant was a 21-year-old man who repeatedly engaged in sexual intercourse with a 15-year-old girl. In September of 2014, Butler was charged with statutory sexual assault, criminal use of a communication facility, manufacturing child pornography, and corruption of minors. In July of 2016, he pleaded guilty to statutory sexual assault and corruption of minors. As a result of pleading guilty to corruption of minors, Pennsylvania law required that he undergo an assessment by the Sexual Offender Assessment Board (“SOAB”) to determine whether or not he fit the classification as an SVP. § 9799.24(a) of SORNA requires that every defendant who is convicted of a sex offense undergo the SOAB evaluation before sentencing for a SORNA offense. The SOAB concluded that Butler was a Sexually Violent Predator, leading to a hearing before the trial judge on the issue. After the SVP hearing, the trial judge found that the Commonwealth met its burden, and the judge classified Butler as a Sexually Violent Predator. Butler also received a sentence of 12 to 30 months of incarceration and 90 months of probation. He appealed. 

How Does Someone Get Labeled AN SVP?

As stated above, after a conviction for a SORNA offense an individual must be assessed the SOAB to determine whether they meet the classification as an SVP. According to § 9799.12 of the SORNA, an individual who is an SVP is a person with “a mental abnormality or personality disorder that makes the individual likely to engage in predatory sexually violent offenses.” In making its assessment, the SOAB will look at 15 factors to determine whether someone meets the classification as an SVP. § 9799.24 lists factors that the SOAB will consider including: the specific facts of the underlying case, the age of the defendant, the age of the complainant, the prior criminal record of the defendant, drug use, whether the defendant has any mental health illnesses. 

If the SOAB makes its determination that an individual meets the requirements for SVP classification, the District Attorney must then file a praecipe to have a hearing before a judge to determine whether or not the defendant should be labeled an SVP. Notably, the Commonwealth must meet this burden by clear and convincing evidence. This is a lesser standard than the beyond a reasonable doubt standard which is required to convict someone of a criminal offense. Further, a defendant does not have the right to have a jury determine whether the defendant is an SVP.

At the SVP hearing, the Commonwealth will present its case as to why the court should find the defendant an SVP. Typically, this involves testimony from the SOAB evaluator who assessed the defendant. The defendant would have the opportunity to cross-examine any witnesses the Commonwealth presents, and the defendant may also present evidence as to why he or she does not meet the characteristics of an SVP. For example, a defendant may call an expert witness to testify that based on an independent assessment of the relevant facts, it is their expert opinion that the defendant is not an SVP. After all the evidence is presented, the statute permits the judge to make a determination, using the clear and convincing evidence standard, as to whether or not the Commonwealth proved that the defendant is a Sexually Violent Predator.  

It is important to note that the SVP procedure can result in even defendants who were convicted of relatively minor sex offenses like misdemeanor Indecent Assault being labeled as SVPs. In most cases, Indecent Assault results in a defendant being required to register as a Tier I Sex Offender. Tier I Sex Offenders face the fewest restrictions in terms of registration requirements and only have to register for fifteen years. However, the SVP procedure can result in someone who would normally be a Tier I Sex Offender being required to register for life subject to the most severe restrictions as a Sexually Violent Predator. 

What Are the Consequences of Being Labeled an SVP?

If a court finds that an individual is an SVP, there are several consequences. First, the defendant must register for life. Further, the victim of the underlying offense must be notified of where the defendant lives and works; the community also receives notification about where the individual lives, works, eats, attends school, spends his or her leisurely time; and the person is subjected to lifetime counseling. As such, this designation carries serious collateral consequences beyond just a period of incarceration or probation. 

For a considerable period of time, Pennsylvania courts held that these registration requirements were civil, rather than punitive in nature. However, this all changed with the Pennsylvania Supreme Court’s landmark decision in Commonwealth v. Muniz, 164 A.3d 1189 (Pa. 2017).   

The Pennsylvania Superior Court Finds § 9799.24 Unconstitutional   

In Muniz, the Pennsylvania Supreme Court held that the SORNA registration requirements were punitive and not civil. This is significant because the United States Supreme Court in Alleyne v. United States held that any fact that increases the mandatory minimum for a sentence must be proven beyond a reasonable doubt. In other words, the state must prove every element of the offense (including facts that increase a sentence) beyond a reasonable doubt.    

In Butler, had there been no SVP hearing, appellant would have had to register for 15 years.  However, because he was classified as an SVP, he had to register for life. Thus, the Butler Court held that this punishment was illegal because the court did not make its determination based on the beyond a reasonable doubt standard and because the statute allows the judge to make the determination instead of giving the defendant the right to a jury. 

The Pennsylvania Superior Court did not limit its ruling to Butler's specific case. Instead, it halted all future SVP hearings. The Court reasoned that because § 9799.24 is inherently flawed, trial courts are no longer allowed to hold SVP hearings until the General Assembly revises the statute to make it compliant with both the Pennsylvania and United States Constitutions.

Award-Winning Philadelphia Criminal Defense Lawyers for Sex Crimes and SORNA Offenses

Philadelphia Criminal Defense Lawyers

SORNA cases can be very complicated, and there is no question that the consequences are dramatic. If you are charged with a SORNA offense, you need an attorney who has the knowledge and expertise to defend your case. Likewise, if you are improperly classified under the SORNA statute, you need an attorney who can help you fix your registration tier. It is not clear whether the Commonwealth will appeal the decision in Butler or whether defendants who have already been classified as SVPs will be required to file a PCRA Petition within sixty days of the decision. Thus, it is important to act quickly in order to avoid waiving any rights to re-classification. Our award-winning Philadelphia criminal defense lawyers have successfully fought countless cases at trial and on appeal. We offer a free 15-minute criminal defense strategy session to any potential client who is under investigation or facing active criminal charges, and we offer a $100 Megan's Law/SORNA consultation on whether we may be able to help you change your registration tier. Call 267-225-2545 to discuss your case with an experienced and understanding criminal defense attorney today. 

Pennsylvania Supreme Court Justices Can’t Agree On Admissibility of Hearsay At Preliminary Hearing

Is Hearsay Admissible at a Preliminary Hearing? 

The Pennsylvania Supreme Court has just dismissed the appeal in Commonwealth v. Ricker, thereby failing to decide the issue of how much hearsay may be admitted at a preliminary hearing in order for the Commonwealth to establish a prima facie case. The use of hearsay by the prosecution at a preliminary hearing has long been a heavily contested issue. For years, the rule was that the prosecution could introduce some evidence via hearsay testimony in order to establish a prima facie case, but the prosecution could not have a defendant held for court and a case sent to the Court of Common Pleas for trial without at least some live testimony by a witness with personal knowledge.

The Use of Hearsay at the Preliminary Hearing and the Pennsylvania Rules of Criminal Procedure

That basic rule began to change in 2011 when the Pennsylvania Supreme Court issued new Rules of Criminal Procedure expressly allowing for the use of hearsay to prove the elements of ownership and non-permission in cases involving property crimes like Theft, Burglary, and Robbery. In order to prove Theft, the prosecution would normally have to show that the defendant took someone else’s property without permission and did not intend to give it back. This would often require two witnesses. First, the complainant who had the property stolen would have to testify that something that person owned was stolen and that the complainant did not give the person who took the property permission to take it. Second, the police officer who arrested the defendant in possession of the stolen property would testify that the officer arrested the defendant and the defendant had the stolen goods.

By permitting ownership and non-permission testimony to come in through hearsay, the rule allowed the Commonwealth to call only the professional police witness, who is more likely to appear for court because it is part of his or her job, to testify at the preliminary hearing. This allowed more cases to survive the preliminary hearing because the complaining witness would only be required for trial. Of course, many cases do not go to trial, leaving many defendants forced to decide whether or not to plead guilty without any meaningful chance to challenge the evidence against them. Before the Pennsylvania Supreme Court adopted the rule, judges would frequently dismiss cases because the owner of the property or house involved in a Burglary or Theft would fail to appear for court. The rule was an attempt to provide the defendant with a continued right to a meaningful hearing while at the same time lessening the burden on victims and witnesses to miss work and other obligations for multiple pre-trial court dates.

Shortly after enacting the 2011 rule, the Pennsylvania Supreme Court amended the rule to permit other types of testimony to come in to evidence via hearsay. The rule currently reads:

Hearsay as provided by law shall be considered by the issuing authority in determining whether a prima facie case has been established. Hearsay evidence shall be sufficient to establish any element of an offense, including, but not limited to, those requiring proof of the ownership of, non-permitted use of, damage to, or value of property.

The amended rule expanded the number of cases in which hearsay could be used to prove various elements of the charged offenses at the preliminary hearing. Nonetheless, important protections remained in effect because the rule did not state that hearsay could be used to prove every element or all elements of an offense, and the Pennsylvania Supreme Court had previously ruled that a case could not be held for court at the preliminary hearing based on hearsay alone.

Commonwealth v. Ricker and Commonwealth v. McClelland

That all changed in the recent cases of Commonwealth v. Ricker and Commonwealth v. McClelland. In Ricker, the Pennsylvania Superior Court held that the amended rule permits the Commonwealth to establish a prima facie case at a preliminary hearing based on hearsay alone. Ricker did not address whether the Pennsylvania and United States Confrontation Clauses, which provide criminal defendants with the right to confront (meaning cross-examine) their accusers, prohibit the Commonwealth from establishing a prima facie case at a preliminary hearing based solely on hearsay. Unfortunately, in McClelland, a panel of the Superior Court again found that the Commonwealth could establish a prima facie case based solely on hearsay because the Confrontation Clause does not apply at a preliminary hearing.

The defense appealed in both Ricker and McClelland, and the defense bar has been anxiously awaiting the Pennsylvania Supreme Court’s review of the Ricker decision. Unfortunately, the Pennsylvania Supreme Court just announced that it has decided to punt on the issue. Instead of determining exactly how much hearsay is allowed at a preliminary hearing, the Supreme Court dismissed the appeal in Ricker as “improvidently granted.” In a concurring opinion, Chief Justice Saylor explained that the Court simply could not agree on a result and felt that the Ricker case was not the appropriate vehicle for resolving all of the issues. In a dissenting opinion, Justice Wecht argued that the Court should have resolved the issue either way and that the Superior Court’s holding in Ricker should be reversed. Because the Court has refused to rule on the issue for now, the exact procedure which should be used at a preliminary hearing will continue to be the subject of litigation.  

Despite the PA Supreme Court’s refusal to resolve the issues in Ricker, the Petition for Allowance of Appeal is still pending in McClelland. Therefore, it remains a possibility that the Court could still resolve these issues. The Court could provide an authoritative ruling on exactly how much hearsay is permitted at a preliminary hearing either by revisiting the issue in McClelland or by engaging in the rule-making process to make the Rules of Criminal Procedure clearer. In the absence of action by the Court, criminal defendants throughout Pennsylvania will remain subject to a wide variety of preliminary hearing procedures and subject to a severe disadvantage in terms of the defense’s ability to test the strength of the Commonwealth’s case at the preliminary hearing.

Most Judges in Philadelphia Require More Than Just Hearsay

In Philadelphia, most judges continue to require some level of non-hearsay testimony, and it is important to note that the rules and the case law do not require a judge to permit the Commonwealth to proceed based solely on hearsay. Instead, McClelland instructs judges to continue evaluating and analyzing the reliability of the Commonwealths’ evidence. Given the high volume of cases, it seems likely that this practice will continue for most cases. Further, many of the most serious cases in Philadelphia such as Attempted Murder and Robbery cases are now charged by way of a secret (and probably even more unfair) Indicting Grand Jury at which the defense is not present or able to cross-examine witnesses instead of by preliminary hearing. In the suburban counties, magistrates are more likely to allow the prosecution to proceed based solely on hearsay. In the short term, the practice in Philadelphia may not change dramatically. In the long term, it remains to be seen whether prosecutors will continue to call witnesses at preliminary hearings and whether the Pennsylvania Supreme Court will revisit this issue.

AWARD-WINNING PHILADELPHIA CRIMINAL DEFENSE LAWYERS

Goldstein Mehta LLC Philadelphia Criminal Defense Attorneys

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. 

Lineup Motions in Philadelphia

In many cases involving charges like Robbery, Aggravated Assault, and Burglary, an eyewitness’s ability to make an identification is the key issue in the case. Numerous studies have shown that eyewitness identification testimony, which is often accepted without hesitation by judges and juries as the best kind of evidence, is actually tremendously unreliable and the number one cause of false convictions. In the overwhelming majority of DNA-based exonerations, the defendant was convicted on the basis of a misidentification by an eyewitness or complaining witness who claimed to be absolutely certain that the defendant committed the crime.

Fortunately, courts have increasingly begun to recognize that eyewitness identifications are often mistaken. In most cases, the eyewitnesses truly believe that the defendant committed the crime, but they have made a terrible mistake. This can happen for any number of reasons, including human fallibility and problems with memory as well as undue police influence even where the police mean well. For this reason, the Philadelphia Police Department and other law enforcement agencies have begun to improve their identification procedures. For example, most Philadelphia Detectives now take steps to tell the complainant or eyewitness that the suspect may not be in a photo array, they show photos one at a time so the photo can be compared to memory instead of other photos on the page, and the photo array is conducted by a detective who does not know who the suspect is and therefore cannot subconsciously influence the witness’s identification.

What is a motion for a lineup?

Zak T. Goldstein, Esq. - Philadelphia Criminal Lawyer

 In addition to these new procedures, there is a critical motion which can be made by the defense at the preliminary hearing in Philadelphia felony cases. Prior to the preliminary hearing in a case in which there will be some kind of eyewitness identification, the defense attorney may make a motion for a lineup. If the motion is granted, the complainant or eyewitness will be required to attend a lineup at the Curran-Fromhold Correctional Facility and attempt to make an identification of the defendant prior to the preliminary hearing. These pre-trial lineups can be extremely important. If the complainant is unable to make an identification or identifies the wrong person, then the misidentification or failure to ID could have a dramatic impact on the case.

Winning a lineup motion in Philadelphia

Bringing a lineup motion does not require filing anything in writing in the Municipal Court because all motions are made orally. Instead, the defense attorney must inform the judge that the attorney has a motion for a lineup when the case is first called in the morning. If the prosecution agrees that a lineup is appropriate, then the judge will order a lineup and continue the preliminary hearing so that the lineup may occur. This is rare as the prosecution almost always opposes the lineup request due to the delay it causes in the case and the fact that a misidentification could be fatal to the case.

Therefore, once the defense makes the lineup motion, the prosecution will typically provide the Municipal Court judge with a summary of the evidence against the defendant and provide reasons for why the lineup request should be denied. The defense lawyer will then be given the opportunity to respond and argue that a lineup is necessary to protect the defendant (and Commonwealth) from a false identification. In some cases, the judge may want to question the witness about the circumstances of the identification and may allow the attorneys for each side to do so, as well.

The case of Commonwealth v. Sexton suggests some of the main factors that a court should consider in ruling on a lineup request and the remedy for when a lineup request is improperly denied. These factors include:

• Do the witness and defendant know each other? Have they seen each other before such that the witness knows what the defendant looks like? This question includes whether some type of identification has already occurred. If the police conducted a “show up” immediately after the incident where the witness was shown and identified the defendant, then the lineup may not be as helpful because the witness already knows what the defendant looks like and believes the defendant committed the crime. Likewise, if the defendant and witness know each other, the lineup will not be particularly useful.
  

• The witness’s opportunity to observe during the incident. This includes factors such as the length of the incident, whether the case involves a cross-racial identification, whether a weapon was involved, how close to each other the witness and suspect were, whether a weapon like a gun was involved, and whether the suspect had anything obscuring his or her face.
  

• Is there other strong evidence against the defendant? For example, if the witness would make a somewhat questionable identification but the defendant is also clearly on video committing a Robbery or Aggravated Assault, then the judge is likely going to find that the delay caused by ordering a lineup is not worth it.

In order to win a lineup motion in Philadelphia, the defense attorney must be able to make a strong argument that based on these factors, the likelihood of a misidentification makes the delay caused by the lineup worth it. For example, Attorney Goldstein recently won a lineup motion in the case of Commonwealth v. R.R. by arguing that a lineup was necessary because the alleged robbery took place in the dark at 2 am, lasted for less than a minute or two, the witnesses and defendants did not know each other, the case involved a cross-racial identification, and a gun was used. Further, there was very little corroborating evidence against the defendants other than the identification. Therefore, the Court granted the lineup motion.

What Is A Lineup?

Once ordered by the Court, the lineup will take place at 5 pm on a weekday at the Curran-Fromhold Correctional Facility on State Road. The defense will be allowed to pick five “fillers” for a lineup of six people, including the defendant. The fillers will typically be inmates at the prison, and the defense attorney must be careful to help the defendant pick fillers who look similar to the defendant. The witness will then be shown the lineup through one-way glass and asked if they identify anyone. The witness’s response will be documented by both the defense attorney, the assigned prosecutor, and a Philadelphia Police Detective.

Will the case get dismissed if the witness fails to pick me out at a lineup?

The prosecution is not required to withdraw the case just because the witness fails to identify the defendant at a lineup. In some cases, they will do so, but in others, they will not. It depends on the strength of the initial identification and whether the prosecution has other evidence. For example, if one witness fails to identify the defendant, but another witness will be able to identify the defendant or the defendant was caught in possession of the proceeds of the burglary, then the prosecution may be able to proceed to trial even without the identification from the witness who failed to pick out the defendant. In other cases, the prosecution will still argue that the initial identification in which the witness picked the defendant out at a show up or out of a photo array was more accurate than the lineup. Each case is different, and whether the prosecution chooses to proceed despite the failure to identify at the lineup will vary depending on all of the circumstances of the case.

Can anything be done if the judge improperly denies the lineup motion or the prosecutor gives incorrect information during argument on the motion for a lineup?  

There is a remedy in cases where a lineup should have been ordered but was not, but it is typically not going to be dismissal of the case or suppression of the identification. In cases where the prosecutor in fact made knowingly false representations, it may be possible to successfully move for dismissal of the case or exclusion of the identification. However, in the more common case in which the prosecutor made a mistake or the evidence turned out to be different than expected, the Supreme Court has suggested that the jury should receive a jury instruction. The jury instruction in this type of case directs the jury to consider the identification of the defendant with caution and may inform the jury of some of the potential problems with eyewitness identifications. Most jurors do their best to follow the judge’s jury instructions carefully. This means that jury instructions are extremely important. In a close case, a jury instruction directing the jury to view the identification with caution could be the difference between a conviction and an acquittal.  

Award-Winning Philadelphia Criminal Defense Lawyers for Lineup Motions

Philadelphia Criminal Defense Attorneys Zak T. Goldstein, Esq. and Demetra Mehta, Esq.

Lineup motions are most common in Robbery, Burglary, and Assault cases. Our award-winning Philadelphia criminal defense attorneys have successfully represented hundreds, if not thousands, of clients in these serious cases. We have won dozens of lineup motions and taken countless cases to trial before judges and juries throughout Pennsylvania. We offer a free 15-minute criminal defense strategy session to any potential client who is facing criminal charges or may be under investigation. Call 267-225-2545 to speak with one of our experienced, understanding defense attorneys.  

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PA Superior Court Reverses Order Granting Motion to Suppress For Lack of Specificity in Grounds

What is a Motion to Suppress? 

The Motion to Suppress is one of the first lines of defense in any case in which the defendant is charged with possessing some kind of contraband. For a defendant who is charged with the possession of guns or drugs, it may be possible to have the evidence excluded from trial and the charges dismissed if the defendant was subject to an illegal search or seizure. In cases where the prosecution is unable to show that police or other law enforcement officers found the evidence in a manner that complies with the requirements of the United Sates and Pennsylvania Constitutions, the evidence could be suppressed by filing a Motion to Suppress. However, Pennsylvania appellate courts have increasingly required defendants to be very specific when asserting the grounds for the Motion to Suppress in the trial court.

Commonwealth v. Banks

In the case of Commonwealth v. Banks, the Superior Court has reversed an order suppressing a firearm and K2 (synthetic marijuana) whichallegedly belonged to the defendant. The Court concluded that although the trial court found that a constitutional violation had occurred, the defendant’s attorney failed to specifically allege that particular constitutional violation either in his written Motion to Suppress or oral statement of the grounds for the Motion which was made prior to the hearing. Accordingly, the Court found that the Commonwealth did not have a fair opportunity to respond to the alleged constitutional violation, and therefore the suppression order should be reversed.

Banks involved a parole search by Pennsylvania State Parole Agents. According to the agents involved, the Parole Board received an anonymous tip that Banks was violating his parole. Based on the tip, two agents went to Banks’ house and knocked on the door. When Banks emerged from the house, the parole agents questioned him on the front porch. They did not see any contraband in the house when the door was open, and they did not enter the house until after they spoke with Banks. Of course, when the agents asked whether Banks had anything in his house which would violate his parole, Banks freely told them that he had a gun and some synthetic marijuana in the house. Following Banks admissions, the agents entered the house and found the contraband. They then called the police. The police obtained a search warrant and recovered the items.

Standards for Probation Searches and Parole Searches

In Pennsylvania, probation officers and parole agents may conduct two types of searches. They may always make routine home visits in order to check on the probationer or parolee and look for any obvious parole violations. Home visits are limited to a plain-view inspection of a residence. Additionally, if they have reasonable suspicion of a parole violation, then parole agents may conduct a full search of the parolee’s residence. In general, anonymous tips do not provide reasonable suspicion because there is no basis for believing them to be trustworthy. Therefore, Banks’ attorneys filed a Motion to Suppress alleging that the firearm and K2 should be suppressed because the parole agents conducted a home search without reasonable suspicion. They further argued that the search was not part of a routine home visit because the agents went out to the house specifically to investigate the anonymous tip.

The trial court disagreed with Banks’ lawyers in part. The court found that the agents violated Banks’ rights, but for different reasons than those alleged in the Motion to Suppress. It found that the agents did not conduct a home search until after Banks confessed to having a gun and synthetic marijuana, and once Banks confessed, the officers clearly had reasonable suspicion to enter the house. However, the court found that the officers conducted the equivalent of a “Terry” stop on Banks by ordering him to come out of the house and submit to their questions. Therefore, the officers were required to have reasonable suspicion for the stop. Because the stop was based entirely on an anonymous tip, the officers did not have reasonable suspicion, and the contraband that they found was the fruit of the poisonous tree and should be suppressed.

Specificity in Motions to Suppress

On appeal, the Superior Court reversed. The Superior Court found that Banks’ lawyers had failed to comply with Rule 581(D) of the Pennsylvania Rules of Criminal Procedure. Under the rules, the defense must “state specifically and with particularity the evidence sought to be suppressed, the grounds for suppression, and the facts and events in support thereof.” In their written motion and subsequent oral grounds, the lawyers mentioned only the suspicion-less search of the residence. They never made any allegation that the interrogation on the porch was conducted without the requisite level of reasonable suspicion. Therefore, the Superior Court held that the Commonwealth was not properly on notice of the grounds for the motion and did not have a fair opportunity to respond. The Court reversed the granting of the motion and remanded the case for trial. It is unclear whether Banks will be able to amend the grounds and re-litigate the motion in the trial court. However, his lawyers will almost certainly try.

Banks is highly illustrative of the fact that the Superior Court is not currently very sympathetic to criminal defendants. The case also shows the importance of litigating in the trial court with a careful focus on the Rules of Criminal Procedure and an eye on making sure that the defendant’s rights are protected in the event of an appeal by either side. If an appellate court can avoid a difficult issue such as whether a gun was properly suppressed by finding waiver on the part of the defense, an appellate court will often do so. Judges do not want to suppress guns, and they will look for ways to avoid doing so. Therefore, it is important to make sure that all possible grounds for a motion to suppress are covered both in the written motion and orally prior to trial. It is also critically important to take all possible steps to protect the record for appeal, which means making appropriate objections and motions so that they are not waived in the event the defendant is convicted at trial.

Award-Winning Philadelphia Criminal Lawyers

Criminal Defense Lawyers Demetra Mehta and Zak Goldstein

If you are facing criminal charges, we can help. Our Philadelphia criminal defense lawyers have successfully represented thousands of clients in both trial and post-trial proceedings. We have won motions to suppress guns, drugs, and other contraband. We will do everything we can to fight for you and obtain the best possible result at trial or on appeal. Call 267-225-2545 for a free criminal defense strategy session today.