Com. of PA v. R.A. Prentiss, 315 A.3d 255

Richard A. Prentiss won a raffle for a special elk hunting license and was guided by professionals during a hunt in Clearfield County, Pennsylvania.
On September 13, 2019, Prentiss shot and killed a bull elk approximately 10 feet from the edge of a public road after exiting his vehicle, with the scene filmed for a potential documentary.
Prentiss was cited by the Pennsylvania Game Commission for two violations: (1) shooting on or across a highway within 25 yards after alighting from a vehicle (Section 2504(a)), and (2) unlawful taking/possession of wildlife (Section 2307(a)).
Prentiss challenged the citations in the trial court, arguing that the Section 2307(a) citation was insufficiently specific and that his actions did not constitute illegal "road hunting" under Section 2504(a).
The trial court found him guilty on both charges; Prentiss appealed to the Commonwealth Court.

Issue	Prentiss's Argument	Commonwealth's Argument	Held
Sufficiency of Section 2307(a) citation (notice)	Citation lacked specificity re: offense	Provided enough info; no prejudice	Citation insufficient—conviction reversed
Sufficiency of evidence for "road hunting" (2504(a))	No quick exit/shooting, no danger posed	Two minutes = "road hunting" violation	Any shooting after exiting vehicle within 25 yards is a violation—conviction affirmed
Application of rule of lenity to ambiguous penal statute	Section 2504(a) ambiguous, should favor defendant	Statute clear on conduct prohibited	Rule of lenity inapplicable; statute not grievously ambiguous

Commonwealth v. Payne, 995 A.2d 1239 (Pa. Super. 2010) (construed Section 2504(a) as prohibiting only reckless, immediate "road hunting" endangering road users)
Commonwealth v. Redovan, 227 A.3d 453 (Pa. Cmwlth. 2020) (summary offense citation must specify nature of prohibited conduct for adequate notice)
Borough of Walnutport v. Dennis, 114 A.3d 11 (Pa. Cmwlth. 2015) (dismissal of citation for defect requires prejudice to defendant)