Pennsylvania v. Barbour (majority)Annotate this Case
The Pennsylvania Supreme Court has held previously that this Court held that a criminal defendant’s failure to appear at a trial scheduled within the time period provided by the speedy trial guarantee of the Pennsylvania Rules of Criminal Procedure constitutes a waiver of that defendant’s right to seek a remedy under that rule. In this case, the Court considered whether the "Steltz" waiver rule applied to a defendant who absented himself from an untimely trial—one that violated Rule 600 before the defendant failed to appear. The Superior Court determined that the Steltz rule applied without regard to the timeliness of the trial, and accordingly reversed the order of the Court of Common Pleas granting Darel Barbour relief under Rule 600. The Supreme Court concluded the Steltz rule was inapplicable. Consequently, the Court reversed the order of the Superior Court.