Com. v. Christman, J., 225 A.3d 1104

Appellant Joseph Christman pled guilty to 11 counts of possession of child pornography (18 Pa.C.S. § 6312(d)), each count based on one video.
The Sentencing Guidelines treat each video as 50 images; Christman thus had 11 videos = 550 images in the prosecutor’s tally.
Trial court applied the Sexual Abuse of Children Enhancement (204 Pa. Code §§ 303.10(e) & 303.9(l)(1)), adding an 18‑month enhancement to each count based on >500 images and imposed an aggregate 36–72 month term.
Christman’s initial direct appeal was denied as a waived discretionary‑aspects challenge; he obtained PCRA relief based on ineffective assistance, reinstating his post‑sentence and direct appeal rights.
On renewed review, the Superior Court held the enhancement must be applied to each conviction separately; because each count involved 50 images, none exceeded 50 and the 18‑month enhancement did not apply. The sentence was vacated and remanded for resentencing without the enhancement.

Issue	Christman (Appellant)	Commonwealth (Appellee)	Held
Whether the court may aggregate images across separately charged counts to determine eligibility for the Sexual Abuse of Children enhancement	Enhancement applies only to each violation; because each count involved 50 images, enhancement does not trigger	Enhancement looks to total images possessed by offender; totals (550) trigger >500 threshold and 18‑month addition per count	The enhancement must be applied to each conviction separately; no count exceeded 50 images, so the 18‑month enhancement did not apply

Rhoades, 8 A.3d 912 (Pa. Super. 2010) (discretionary‑aspects standard and substantial‑question requirement for appellate review)
Moury, 992 A.2d 162 (Pa. Super. 2010) (abuse‑of‑discretion standard for reviewing a sentence)
A.S. v. Pennsylvania State Police, 143 A.3d 896 (Pa. 2016) (plain‑meaning rule governs statutory interpretation; review is plenary)
Davidson, 860 A.3d 575 (Pa. Super. 2004) (separate convictions and sentences prevent a “volume discount”)