Com. v. Austin, A., 327 EDA 2017

Alvin Austin was on probation for prior PWID convictions (2005, 2008) with warnings that further violations could result in state incarceration.
He repeatedly absconded from supervision, tested positive for drugs multiple times, and had prior county sentences and IP program placements aimed at treatment.
After a 2016 arrest, Austin failed to appear for scheduled probation/status hearings and tested positive for cocaine and marijuana; probation officer recommended revocation.
At the revocation hearing Austin acknowledged relapse, said he needs treatment, and urged a county sentence with treatment; defense emphasized family ties and work.
The court found a technical violation, revoked probation, and imposed concurrent state sentences of 2½ to 5 years on each count (to run concurrent), recommending placement at SCI–Chester for treatment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 2½–5 year state sentence following probation revocation was unreasonable/manifestly excessive	Commonwealth: sentence appropriate given repeated absconding, failure to take advantage of continuance, and need to vindicate court authority	Austin: sentence disproportionate to technical violations and his addiction; county confinement + treatment would better foster rehabilitation	Court: Affirmed — sentence not manifestly excessive; justified to vindicate court authority and address rehabilitation through state treatment

Commonwealth v. Johnson, 125 A.3d 822 (appellate discretion review standard)
Commonwealth v. Coolbaugh, 770 A.2d 792 (sentencing options after probation revocation)
Commonwealth v. Fowler, 930 A.2d 586 (limitations on sentencing after revocation)
Commonwealth v. Mouzon, 812 A.2d 617 (within-statutory-limit sentences not abuse absent manifest excess)
Commonwealth v. Walls, 926 A.2d 957 (appellate reasonableness review; factors to consider)
Commonwealth v. Person, 297 A.2d 460 (standard on abuse of discretion in sentencing)