Commonwealth v. Waugaman
167 A.3d 153
| Pa. Super. Ct. | 2017Background
- On Sept. 12, 2015, Rick Alan Waugaman, in work-release status at Union County Prison, was released early morning to go to work but did not report to his employer.
- Instead he went to his girlfriend’s house, stayed about an hour, then was unaccounted for approximately three additional hours before returning to the prison around 8:00 a.m.
- Prison officials revoked his work-release privileges; the Commonwealth charged him with escape under 18 Pa.C.S.A. § 5121.
- A jury convicted Waugaman of escape on Oct. 6, 2016; the trial court sentenced him on Nov. 30, 2016 to 1–4 years’ incarceration.
- Waugaman challenged (1) sufficiency of the evidence to show a substantial deviation from official detention and (2) that prosecution was barred by double jeopardy because administrative sanctions had already been imposed.
- The trial court denied relief; the Superior Court affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency: whether Waugaman unlawfully removed himself from official detention / substantially deviated from work-release travel | Commonwealth: Waugaman left work-release supervision and was unaccounted for several hours, supporting escape conviction | Waugaman: maintained contact with employer/prison, intended to and did return, so no substantial deviation (relied on Edwards and Hall) | Affirmed — evidence sufficient: going to girlfriend, not to work, and being away ~5 hours was a substantial deviation supporting escape conviction |
| Double jeopardy: whether administrative sanction (loss of work-release) bars criminal prosecution | Commonwealth: prison discipline does not bar subsequent criminal prosecution for escape | Waugaman: removal from work release was punishment for same conduct; prosecution should be barred | Affirmed — forfeiture of privileges is an administrative sanction within the original sentence’s scope and does not preclude criminal prosecution (per McGee) |
Key Cases Cited
- Commonwealth v. Edwards, 595 A.2d 183 (Pa. Super. 1991) (work-release participation is official detention; escape requires substantial deviation)
- Commonwealth v. Hall, 585 A.2d 1117 (Pa. Super. 1991) (discusses deviations from prescribed travel route in work-release context)
- Commonwealth v. Williams, 153 A.3d 372 (Pa. Super. 2016) (standard for appellate review of sufficiency of the evidence)
- Commonwealth v. McGee, 744 A.2d 754 (Pa. 2000) (prison disciplinary action under administrative scheme does not bar subsequent criminal prosecution)
- Commonwealth v. Morman, 541 A.2d 356 (Pa. Super. 1988) (noting habeas corpus as means to test prima facie sufficiency pretrial)