Commonwealth v. Reid, 35 A.3d 773

Pennsylvania appeals order dismissing Case 264 under Section 110 Crimes Code.
Appellee Reid confessed in 2006 controlled buy that connected to a larger drug distribution enterprise.
Case 264 charged two PWID counts and one conspiracy offense for 2006–2007 acts.
Grand jury presentment later described Reid selling cocaine from his house and bars with a middleman.
Trial court dismissed Case 264; Commonwealth timely appealed.
Nolan framework used to analyze whether cases involve a single criminal episode or multiple episodes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Case 264 and Case 79 share the same criminal episode under §110	Commonwealth: ongoing enterprise; substantial overlap in activity warrants joinder	Reid: separate episodes; different victims and movers; not same episode	No; they constitute multiple episodes; reverse for reinstatement of Case 264

Commonwealth v. Fithian, 599 Pa. 180, 961 A.2d 66 (Pa. 2008) (four-element test for former prosecution bar under §110(l)(ii))
Commonwealth v. Nolan, 579 Pa. 300, 855 A.2d 834 (Pa. 2004) (enterprise vs. single episode; avoid volume discounting)
Commonwealth v. Hude, 500 Pa. 482, 458 A.2d 177 (Pa. 1983) (logical and temporal relationship governs same-episode analysis)
Commonwealth v. Kaminski, 342 Pa. Super. 37, 492 A.2d 51 (Pa. Super. 1985) (same contraband to same officer; multiple charges timely filed)
Commonwealth v. Rocco, 375 Pa. Super. 330, 544 A.2d 496 (Pa. Super. 1988) (continuous undercover investigation; single episode finding)
Commonwealth v. McPhail, 547 Pa. 519, 692 A.2d 139 (Pa. 1997) (three months activity; major mover; different context)