Com. v. Russell, J., 1247 WDA 2024

Joseph Russell was convicted of public drunkenness after an incident at the Wicked Googly bar in Ligonier, Pennsylvania.
Witnesses, including a bartender and manager, testified that Russell was loud, disruptive, refused to leave, and interfered with bar service.
Police arrived to find Russell confrontational with visible signs of intoxication (odor of alcohol, slurred speech, stumbling), refused to leave, and blocked access to the bathroom.
Russell acted pro se throughout; his pretrial motions challenging the legality and jurisdiction of his arrest were denied post-trial.
The trial court convicted Russell of public drunkenness, fined him $150, and dismissed the disorderly conduct charge; Russell appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Consideration of post-detention evidence	Evidence after detention can't support conviction; not voluntarily public	Only conduct before escort from the bar was considered	No relief: verdict based only on pre-escort conduct
Sufficiency of evidence for public drunkenness	No proof of annoyance/endangerment; lawful to dispute bill	Witnesses & officers proved he was drunk and disruptive	Sufficient evidence; conviction affirmed
Authority for warrantless arrest under § 8902	No ongoing imperiling conduct; no proper guidelines; arrest unauthorized	Probable cause existed based on observed conduct and danger	Probable cause present; procedural guidelines claim waived

Commonwealth v. Meyer, 431 A.2d 287 (Pa. Super. 1981) (holding a person must voluntarily be in a public place to be convicted of public drunkenness)
Commonwealth v. Peralta, 311 A.3d 1 (Pa. Super. 2024) (setting the standard for appellate review of evidentiary sufficiency)
Commonwealth v. Goldman, 252 A.3d 668 (Pa. Super. 2021) (framework for reviewing the lawfulness of a warrantless arrest)