Commonwealth v. Edwards
71 A.3d 323
| Pa. Super. Ct. | 2013Background
- Appellant Calvin Edwards, seventeen at sentencing, was found in violation of probation and revoked, receiving a 42.5 to 85-year aggregate term.
- The court initially imposed the sentence on August 19, 2009, then vacated/reconsidered it and held a second hearing on December 16, 2009.
- Evidence included expert testimony from Gillian Blair, Ph.D., on adolescent brain development and risk factors for reoffending, and Benchmark Behavioral Health records showing long-standing behavioral problems.
- Edwards' conduct at Benchmark included violence, sexualized behavior, and failure to participate in treatment; progress reports showed persistent risk factors.
- The trial court articulated concerns Edwards would pose violence in the community and affirmed the long sentence after reconsideration, finding it necessary to protect the public.
- Edwards appealed, challenging the legality of the sentence under § 9771(c), its excessiveness, and the court’s discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the revocation sentence complied with § 9771(c). | Edwards argues no new crime, no likelihood of reoffense, and no necessity to vindicate authority. | Edwards contends the court failed to find likelihood of future crime and compliance with statutory limits. | No error; sentence permitted under § 9771(c). |
| Whether the 42.5–85 year term for a juvenile was manifestly excessive and failed to consider rehabilitative needs. | Edwards asserts inadequate individualized consideration and overpunishes a juvenile for technical violations. | Edwards acknowledges discretion but claims the court properly weighed factors and risks. | No abuse of discretion; no substantial question established; sentence affirmed. |
| Whether the overall sentence was an excessive display of punishment constituting an abuse of discretion. | Edwards argues disproportionate punishment given youth and rehabilitation prospects. | Court relied on extensive records and expert testimony showing high risk and need for confinement. | Court did not abuse discretion; sentence upheld. |
Key Cases Cited
- Commonwealth v. Sierra, 752 A.2d 910 (Pa. Super. 2000) (review limited to revoke/second-sentencing authority)
- Commonwealth v. Gheen, 455 Pa. Super. 499 (1997) (limits on appellate review after probation revocation)
- Commonwealth v. Coolbaugh, 770 A.2d 788 (Pa. Super. 2001) (three conditions for total confinement post-revocation)
- Commonwealth v. Hoover, 909 A.2d 321 (Pa. Super. 2006) (probation-revocation standards and authority)
- Commonwealth v. Austin, 66 A.3d 798 (Pa. Super. 2013) (discretionary sentencing; substantial question framework)
- Commonwealth v. Dunphy, 20 A.3d 1215 (Pa. Super. 2011) (lack of substantial question for mere non-consideration)
- Commonwealth v. Coulverson, 34 A.3d 135 (Pa. Super. 2011) (excessiveness considerations and victim-impact reliance)
- Commonwealth v. Hill, 66 A.3d 365 (Pa. Super. 2013) (review of excessive sentence and treatment of offender factors)