Commonwealth v. Hansley
47 A.3d 1180
| Pa. | 2012Background
- Defendant pled guilty to two drug-trafficking cases under plea agreements in 2009.
- Case 1808 involved delivery of cocaine within 1,000 feet of a school, triggering a mandatory two-year minimum (18 Pa.C.S. § 6817(a)).
- Case 1809 involved a second cocaine sale and residence search yielding ~24 grams, triggering a three-year minimum (18 Pa.C.S. § 7508(a)(3)(ii)).
- Trial court sentenced 1808 to 2–4 years and 1809 to 3–6 years, to run concurrently; RRRI eligibility was then determined.
- RRRI Act created an eligibility minimum sentence in addition to the mandatory minimum; board parole determinations depend on program completion.
- Commonwealth appealed claiming RRRI cannot apply to these mandatory minimums; Superior Court affirmed RRRI eligibility and constraints.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RRRI applies to mandatory minimums under §6317 and §7508 | Commonwealth: RRRI cannot apply when mandatory penalties exist; would make sentences illegal. | Hansley: RRRI supplements and can operate alongside mandatory minimums; not precluded by conflict. | RRRI applies to the mandatory minimum penalties; RRRI minimums may run in addition to mandatory minimums. |
| Does a conflict exist between RRRI and school-zone drug penalties and which controls | §6317/§7508 express override language should prevail over RRRI. | RRRI is newer and intended to apply to eligible offenders; general v. specific provisions do not override. | RRRI and mandatory penalties can coexist; RRRI not superseded by the school-zone penalties. |
| Is the imposition of RRRI minimum sentences lawful and not illegal under the statute | RRRI minimums import earlier parole opportunities; could render minimums illegal. | RRRI minimums are authorized in addition to minimum sentences; not illegal. | Sentence is lawful; RRRI minimums operate in addition to mandatory minimums. |
Key Cases Cited
- Commonwealth v. Garzone, 34 A.3d 67 (Pa. 2012) (statutory construction guidance in interstatutory interpretation)
- Commonwealth v. Klingensmith, 650 A.2d 444 (Pa. Super. 1994) (specific vs general provisions; pan materia; conflict resolution)
- Commonwealth v. Bradley, 834 A.2d 1127 (Pa. 2003) (illegal sentence only when exceeding statutory limits)