Com. v. Baldwin, T., 675 MDA 2017

Baldwin pleaded guilty in CP-14-CR-0686-2015 to delivery, conspiracy, and criminal use of a communication facility; aggregate sentence 3–6 years, consecutive to a 10–20 year term in CP-302-2014.
CP-302-2014 (original case) charged Baldwin with multiple Controlled Substance Act violations from 2012–2013; severance was granted for counts 6–8 from other counts.
After severance, the Commonwealth filed four new informations; some counts were amended and some were nol pros of others.
Baldwin challenged jurisdiction to accept the plea in CP-0686-2015 while CP-302-2014 remained on appeal.
The trial court denied challenges; Baldwin reinstated appellate rights later via PCRA proceedings and appealed the resulting judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court have jurisdiction to accept Baldwin's guilty plea while CP-302-2014 was on direct appeal?	Baldwin contends lack of jurisdiction due to pending appeal.	Commonwealth argues the court could administer severed charges administratively and preserve status quo.	Yes; administrative action permissible, no jurisdictional error.
Was the Commonwealth barred from amending CP-0686-2015 after severance and trying non-severed counts from CP-302-2014?	Rule 564 violated; amendment prejudiced Baldwin and created double jeopardy risk.	Rule 564 allowed amendment if no new/different offense; facts known; no prejudice.	Amendment proper; no new offense; no reversible error; waiver of double jeopardy applies when severance occurs.

Commonwealth v. Sinclair, 897 A.2d 1218 (Pa. Super. 2006) (Rule 564 amendment allowed when same elements and no prejudice)
Commonwealth v. Dawson, 87 A.3d 825 (Pa. Super. 2014) (severance waives double jeopardy rights to consolidate charges)
Commonwealth v. Cicconi, 653 A.2d 40 (Pa. Super. 1995) (severance and joinder principles in double jeopardy analysis)
Commonwealth v. Duda, 831 A.2d 728 (Pa. Super. 2003) (prejudice avoidance in last-minute amendments to charges)