Com. v. Maze, L., 893 WDA 2016

Larry Maze was convicted by a jury of multiple sexual offenses against three girls aged 12–13, including solicitation via Facebook, unlawful contact, corruption of minors, and indecent assault.
Three separate indictments (consolidated for trial) produced guilty verdicts on all counts on June 16, 2015.
A bifurcated SVP (sexually violent predator) hearing occurred; the trial court later designated Maze an SVP and imposed an aggregate term of 86–270 years’ imprisonment on May 3, 2016.
Maze filed timely post-sentence motions and an appeal with a Pa.R.A.P. 1925(b) statement; the trial court issued a Rule 1925(a) opinion.
On appeal Maze raised (1) that the Commonwealth’s dramatized reading (“skit”) of Facebook messages was unduly prejudicial under Pa.R.E. 403 and (2) that his sentence was excessive and equivalent to life without parole.
The Superior Court found both appellate claims waived for procedural and briefing defects but sua sponte vacated only the SVP designation portion of the sentencing order as illegal under Muniz and related Sixth Amendment precedent, remanding for proper SORNA tiering and notice.

Issue	Appellant's Argument	Commonwealth/Trial Court Argument	Held
Whether the Commonwealth’s live reading/skit of Facebook messages was unduly prejudicial under Pa.R.E. 403	The skit was time-consuming, emotional, and its prejudice outweighed probative value; it improperly sought an emotional jury response	The substance of the messages was admitted and the manner of presentation was not objectionable; counsel’s in-court objection was not specific	Waived for failure to state specific grounds at trial and inadequate appellate briefing; no relief granted on merits
Whether the sentence (86–270 years) and SVP designation were excessive/illegal	Sentence is effectively life without parole and excessive given lack of prior sex offenses and limited physical contact	Sentencing discretion rested with trial court; but SVP designation invokes SORNA requirements	Sentencing challenge waived for inadequate Rule 2119(f) and argument. However, SVP designation vacated sua sponte as illegal under Muniz; remanded to determine SORNA tier and provide proper notice

King v. Pulaski, 710 A.2d 1200 (Pa. Super. 1998) (specific, timely objection required to preserve evidentiary claim)
Commonwealth v. Rodgers, 605 A.2d 1228 (Pa. Super. 1992) (issues undeveloped in brief are waived)
Commonwealth v. Moury, 992 A.2d 162 (Pa. Super. 2010) (four-part test for discretionary aspects of sentencing review)
Commonwealth v. Muniz, 164 A.3d 1189 (Pa. 2017) (SORNA registration is punitive; factual findings increasing punishment must meet constitutional standards)
Apprendi v. New Jersey, 530 U.S. 466 (2000) (facts that increase penalty must be found beyond a reasonable doubt)
Alleyne v. United States, 133 S.Ct. 2151 (2013) (declining facts that increase mandatory minimums to judge-found facts)
Commonwealth v. Sarapa, 13 A.3d 961 (Pa. Super. 2011) (Rule 2119(f) requirements for challenging discretionary sentencing)