Com. v. Robinson, C.
2025 Pa. Super. 127
| Pa. Super. Ct. | 2025Background
- Clinton Robinson was arrested on September 3, 2021, and charged with two counts of persons not to possess firearms.
- The case experienced multiple procedural delays, including motions to suppress, judicial recusals, defense continuances, and inclement weather postponements.
- During the litigation, Robinson’s counsel requested additional DNA "bench work" paperwork more than a year after the initial DNA report was provided.
- The trial court granted Robinson’s motion to dismiss the charges under Pennsylvania Rule of Criminal Procedure 600 (Rule 600), finding the Commonwealth did not exercise due diligence and caused unreasonable delay.
- The Commonwealth appealed, arguing that much of the delay was not attributable to it but rather to defense actions, judicial changes, and other administrative factors.
- The Superior Court reversed the trial court, holding that most delays were excludable under Rule 600 and that only a fraction of the total time was properly attributable to the Commonwealth.
Issues
| Issue | Commonwealth's Argument | Robinson's Argument | Held |
|---|---|---|---|
| Attribution of delays from judicial reassignments | Not attributable to Commonwealth; due to court administration | Commonwealth should monitor and ensure timely trial | Not attributable to Commonwealth |
| Delay due to DNA discovery (bench notes) | Not mandatory discovery; provided promptly after late request | Delay in providing DNA notes delayed defense preparations | Not attributable to Commonwealth |
| Delay from failure to bring Robinson from state custody | Out of Commonwealth's control | Commonwealth responsible to ensure presence | Not attributable to Commonwealth |
| Obligation to track Rule 600 run date and press for trial | No legal duty to show a tracking system existed | Commonwealth should ensure timely prosecution | No such requirement under law |
Key Cases Cited
- Commonwealth v. Bethea, 185 A.3d 364 (Pa. Super. 2018) (abuse of discretion standard for Rule 600 decisions)
- Commonwealth v. Hill, 736 A.2d 578 (Pa. Super. 1999) (delay for defense pretrial motions excludable under Rule 600)
- Commonwealth v. Mines, 797 A.2d 963 (Pa. Super. 2002) (failure to bring defendant from custody not attributable to prosecution)
- Commonwealth v. Herring, 271 A.3d 911 (Pa. Super. 2022) (court congestion and administrative delays excludable under Rule 600)
- Commonwealth v. Bradford, 46 A.3d 693 (Pa. Super. 2012) (Rule 600 analysis considers reasonableness of Commonwealth's efforts)