Pennsylvania v. Wolfe (majority)
Annotate this CaseIn August 2012, Appellee Matthew Wolfe, then eighteen years old, engaged in sexual intercourse with a thirteen-year-old girl on several occasions. He was charged with and convicted by a jury trial for a number of sexual offenses, including two counts of involuntary deviate sexual intercourse. During Appellee’s trial and prior to sentencing, the United States Supreme Court issued its "Alleyne v. United States," (133 S. Ct. 2151 (2013)) decision, overruling its own prior precedent and establishing a new constitutional rule of law, grounded on the Sixth Amendment to the United States Constitution. The Pennsylvania Supreme Court allowed appeal in Wolfe's case to assess the validity of the Superior Court’s sua sponte determination that a sentencing statute was facially unconstitutional under Alleyne. "We are not unsympathetic to the plight of the Commonwealth in Alleyne’s wake, given the volume of the mandatory minimum sentences that must be stricken, and the scale of the task of resentencing. We also appreciate that, in enacting the mandatory minimum sentencing regime, the General Assembly had acted in good faith reliance on the previous jurisprudence of the Supreme Court of the United States, which was discarded by that Court in Alleyne. Nevertheless, new constitutional rules of Alleyne’s magnitude often have unavoidable, wide-scale consequences." Accordingly, the Court affirmed the Superior Court's decision.
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