Com. v. Snyder, R.
Com. v. Snyder, R. No. 1320 WDA 2016
| Pa. Super. Ct. | Aug 1, 2017Background
- Rexford Snyder was charged in March 2015 with multiple motor-vehicle offenses including two DUI counts, driving while privilege suspended (BAC ≥ .02), and careless driving; he pled not guilty and sought jury trial listing.
- Multiple trial listings followed: backups on Sept 30, 2015 and March 15, 2016 (moved due to prior two-day jury trial), then set for April 26, 2016 and continued to May 25, 2016 because the Commonwealth’s expert suffered a medical emergency.
- Snyder filed two pretrial motions to dismiss under Pa.R.Crim.P. 600 (speedy trial); first denied April 21, 2016; second filed May 24, 2016 and denied that day.
- Trial occurred May 25, 2016; jury convicted Snyder; trial court sentenced him July 6, 2016; Snyder timely appealed claiming Rule 600 violation.
- Trial court found mechanical run date was March 16, 2016, but after subtracting excludable (defense-requested continuance), judicial (court’s prior jury trial), and excusable (expert’s medical emergency) delays, the adjusted run date was June 9, 2016 — after Snyder’s May 25 trial.
- Superior Court affirmed, holding the Commonwealth met due-diligence and judicial delay principles under Rule 600; no speedy-trial violation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 600 was violated because trial exceeded 365 days from complaint | Commonwealth: complied with Rule 600 after excluding excludable/excusable/judicial delays | Snyder: multiple available trial dates existed after his request to list; Commonwealth failed to show due diligence for not trying him earlier | No. Court held adjusted run date extended beyond trial date; no Rule 600 violation |
| Whether Commonwealth exercised due diligence for scheduling and prosecuting trial | Commonwealth: showed readiness and that delays were either defense-caused, judicial, or excusable (expert emergency) | Snyder: Commonwealth offered no adequate explanation for not trying case on allegedly available dates | Court found Commonwealth exercised reasonable due diligence; excusable/uncontrollable delays justified extension |
| Whether judicial delay is attributable to Commonwealth | Commonwealth: delay was caused by court’s docket (prior two-day jury trial), not by prosecution | Snyder: asserted calendar could have been rearranged; administrator identified alternate dates | Court treated the 42-day courtroom/judge unavailability as judicial delay excusing Commonwealth and not attributable to prosecution |
| Whether expert unavailability justified excusable delay | Commonwealth: expert’s medical emergency prevented trial despite readiness | Snyder: argued alternative dates existed and Commonwealth didn’t justify missing them | Court ruled illness of key witness is excusable delay if prosecution was ready and due diligence shown |
Key Cases Cited
- Commonwealth v. Thompson, 93 A.3d 478 (Pa. Super. 2014) (standard of review and framing Rule 600 analysis)
- Commonwealth v. Ramos, 936 A.2d 1097 (Pa. Super. 2007) (limitations on appellate review of Rule 600 evidentiary hearing)
- Commonwealth v. Roles, 116 A.3d 122 (Pa. Super. 2015) (adjusted run date concept; subtraction of excludable/excusable time)
- Commonwealth v. Goldman, 70 A.3d 874 (Pa. Super. 2013) (definition of adjusted run date and dismissal standard)
- Commonwealth v. Armstrong, 74 A.3d 228 (Pa. Super. 2013) (due diligence is fact-specific; reasonable efforts required)
- Commonwealth v. Hunt, 858 A.2d 1234 (Pa. Super. 2004) (judicial delay can justify extension if Commonwealth ready)
- Commonwealth v. Brown, 875 A.2d 1128 (Pa. Super. 2005) (continuances at defense request are excludable)
- Commonwealth v. Corbin, 568 A.2d 635 (Pa. Super. 1990) (unavailability of a witness due to illness can be excusable delay)
- Commonwealth v. Weaver, 525 A.2d 785 (Pa. Super. 1987) (similar principle on witness unavailability)
- Commonwealth v. Preston, 904 A.2d 1 (Pa. Super. 2006) (courts are not required to constantly rearrange dockets to meet strict Rule 600 deadlines)