Com. v. Longo, W., 1032 WDA 2015

William C. Longo pled guilty in 2009 to multiple theft, forgery, access-device fraud, receiving stolen property and conspiracy charges; received 9–18 months imprisonment on forgery (paroled) and two consecutive 2‑year probation terms.
No post‑sentence motions or direct appeal were filed after the 2009 sentencing.
Probation was revoked in 2012 for violations; court reimposed a two‑year probation term.
On June 8, 2015 (amended July 6, 2015), after another probation violation, the court found Longo a convicted violator and sentenced him to consecutive terms: 3½–7 years (later corrected to 33–66 months) and 33–66 months, within the original exposure.
Longo appealed, claiming (1) the revocation sentences were manifestly excessive because the court failed to consider his personal history, character, and rehabilitative needs, and (2) the court relied on misinformation or incorrect facts at resentencing.
The trial court had a PSI (Aug. 15, 2014), heard IP evaluations, testimony about Longo’s noncompliance and restitution arrears, and extensive on‑the‑record reasoning for the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation sentences were manifestly excessive / court failed to consider mitigating factors	Longo: court ignored IP assessments, his sobriety, work while jailed, and family support; failed to consider rehabilitative needs	Commonwealth: court considered record, PSI, IP results, and Longo’s extensive noncompliance and criminal history	Affirmed — sentence within statutory bounds; court meaningfully considered relevant factors and acted within discretion
Whether court relied on misinformation or incorrect facts at resentencing	Longo: court made statements implying uncharged crimes and relied on improper facts	Commonwealth: isolated, passing comment did not drive sentencing; court relied on permissible factors (record, violations, character)	Affirmed — no reliance on impermissible factors; passing remark insufficient to invalidate sentence

Commonwealth v. Pasture, 107 A.3d 21 (Pa. 2014) (explains deferential review and unique considerations for sentences after probation revocation)
Commonwealth v. Walls, 926 A.2d 957 (Pa. 2007) (sentencing court presumed aware of PSI and defendant’s relevant background)
Commonwealth v. Sierra, 752 A.2d 910 (Pa. Super. 2000) (standard: sentencing after revocation is within trial court’s discretion)
Commonwealth v. Sypin, 491 A.2d 1371 (Pa. Super. 1985) (sentence invalid if court relies on impermissible considerations)
Commonwealth v. Reaves, 923 A.2d 1119 (Pa. 2007) (Sentencing Guidelines do not apply to revocation sentences)

Judgment of sentence affirmed.