Commonwealth v. Sampolski
89 A.3d 1287
Pa. Super. Ct.2014Background
- Sampolski pled guilty on June 14, 2010 to corruption of a minor, a misdemeanor of the first degree; the conviction did not require Megan's Law registration at that time.
- Commonwealth dismissed other charges that would have required registration under Megan's Law in exchange for Sampolski's guilty plea.
- Trial court sentenced Sampolski to 6–12 months with work release and 4 years' probation.
- By December 2012 Sampolski received notice he would have to register under SOR-NA; PA law had since amended corruption of minors and SORNA applicability.
- Sampolski filed a petition on January 22, 2013 to enjoin SORNA registration; trial court held Sampolski was not required to register and enjoined registration; Commonwealth appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Corruption (Former) an equivalent to Corruption (F3) under 9799.14(b)(21) so Sampolski must register under SORNA? | Commonwealth argues former crime is equivalent to F3 and falls within SORNA’s Tier I | Sampolski argues former crime has different elements and is not equivalent to F3 | Not equivalent; no SORNA registration required. |
Key Cases Cited
- Commonwealth v. Northrip, 603 Pa. 544 (2009) (elements-based equivalency analysis for comparable crimes)
- Commonwealth v. Shaw, 560 Pa. 296 (2000) (policy considerations informative but not controlling in equivalency)
- Commonwealth v. Samuel, 599 Pa. 166 (2008) (standard of review and plenary consideration for statutory interpretation)
- Commonwealth v. Collins, 564 Pa. 144 (2001) (plenary scope and application of statutory analysis)