Commonwealth v. Steffy, 36 A.3d 1109

Steffy was convicted of flight to avoid apprehension and driving under suspension after fleeing from Officer Smith following a traffic stop.
The stop occurred on Route 522 in Snyder County for speeding in a 35 mph zone; the driver’s license, registration, and insurance information were not provided.
A bench warrant for a felony-related probation violation was discovered; Steffy denied knowledge of any arrest warrant.
Steffy fled the scene when handcuffing was attempted; he was apprehended days later.
The trial court sentenced Steffy to three to six years for flight and three to six months for driving with a suspended license; the resisting arrest charge was dismissed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence shows intent to avoid apprehension for a felony.	Steffy argues no knowledge of the warrant’s felony nature; no intent to evade a felony.	Commonwealth contends intent to avoid apprehension existed due to the felony probation warrant.	Yes; intent to avoid apprehension existed, warrant related to a felony probation violation.
Whether knowledge of the underlying felony is required for the felony grading.	Steffy claims lack of knowledge of felony status bars felony grading.	Commonwealth argues awareness is imputable via probation conditions; warrant premised on felony violation.	Knowledge of the underlying felony not required; flight can be graded as felony if the warrant relates to a felony.

Commonwealth v. Hart, 28 A.3d 898 (Pa. 2011) (statutory interpretation; de novo review of flight statute intent element)
Commonwealth v. Sarapa, 13 A.3d 961 (Pa. Super. 2011) (statutory construction; effect to all provisions)
Commonwealth v. Janis, 400 Pa. Super. 280 (Pa. Super. 1990) (distinguishes when underlying felony knowledge is required in grading)
Commonwealth v. Sparks, 737 A.2d 787 (Pa. Super. 1999) (parole violation context supports felony grading when on felony parole)