Commonwealth v. Dixon, 66 A.3d 794

Appellant charged with two stop sign violations and convicted, fined $25 plus costs on each count.
Appellant timely appealed the summary convictions on September 19, 2011, filing notices for each docket.
De novo trials were scheduled for December 7, 2011, with notices specifying time, date, and location at City-County Bldg, 8th Floor, Room 21, 414 Grant Street.
On December 7, 2011, Appellant failed to appear; the trial court dismissed the summary appeal after calling the case.
Appellant filed a notice of appeal on December 15, 2011; the court did not issue a Pa.R.A.P. 1925(b) directive, and later issued a 1925(a) opinion.
Appellant argues dismissal was improper because the court failed to inquire into good cause for absence, relying on Marizzaldi and related authorities.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dismissal for absence without cause was proper	Dixon argues the court failed to inquire into involuntary absence under Marizzaldi.	Commonwealth contends Rule 462 permits dismissal absent cause without automatic remand.	Dismissal affirmed; no prima facie involuntary absence shown.

Marizzaldi v. Commonwealth, 814 A.2d 249 (Pa. Super. 2002) (absence inquiry required; remand for new trial when absence involuntary)
Mesler v. Commonwealth, 732 A.2d 21 (Pa. Cmwlth. 1999) (remand for new hearing when cause for absence not considered)
Commonwealth v. Akinsanmi, 55 A.3d 539 (Pa. Super. 2012) (good cause required for absence; new trial if established)
Commonwealth v. Doleno, 406 Pa. Super. 286, 594 A.2d 341 (Pa. Super. 1991) (precedent on outcomes after absence and inquiry)
Commonwealth v. Asians, 761 A.2d 601 (Pa. Super. 2000) (standard of review for trial court findings)