Pennsylvania v. Cullen-Doyle (majority)Annotate this Case
In 2009, the Pennsylvania General Assembly codified the Recidivism Risk Reduction Incentive Act (the “RRRI Act” or the “Act”), intended to encourage eligible offenders to complete Department of Corrections programs that are designed to reduce recidivism. Eligibility was conditioned, in relevant part, upon the absence of a “history of present or past violent behavior.” The Commonwealth filed a number of informations against Appellant Sean Cullen-Doyle, each charging him with burglary, conspiracy, and theft-related offenses. Appellant pled guilty to several counts of criminal conspiracy to commit first-degree felony burglary and one count of first-degree felony burglary. The court found Appellant ineligible for the RRRI program and sentenced him to three-to-six years’ imprisonment on the burglary conviction, followed by an aggregate fifteen-year term of probation on the conspiracy counts. In a post-sentence motion, Appellant asked the court to reconsider his eligibility for the program. The court denied the motion for reconsideration, referencing Appellant’s “prior first degree burglary conviction,” although it was unclear whether the court was referring to the present offense or another, earlier offense. On appeal, Appellant maintained he was never convicted of burglary on a prior occasion, and the Commonwealth admitted it could not find any indication of such a prior conviction. Therefore, the parties filed a joint motion to remand the matter to the common pleas court to determine whether that court’s ruling was based on inaccurate information concerning Appellant’s criminal record. The Superior Court acknowledged the confusion on this point but found the uncertainty immaterial and denied the motion, concluding that Appellant was ineligible for the RRRI program based solely on his present conviction for a crime of violence. The Pennsylvania Supreme Court concluded the RRRI Act was a statute subject to the rule of lenity, thus any ambiguity surrounding the meaning of the word “history” (as was deemed an issue here) should have been resolved in favor of those seeking admission into the program. The Court reversed the Superior Court and remanded for further proceedings.