Pennsylvania v. Johnson (majority)
Annotate this CaseThis appeal concerned the application of the statutory compulsory joinder rules, which generally require a prosecutor to pursue, in a single proceeding, all known charges against a defendant arising from a single criminal episode occurring within the same judicial district, subject to enumerated exceptions. In 2015, as the result of a traffic stop, Appellant Dewitt Johnson was arrested and charged with driving with a suspended license, possession with intent to deliver heroin (“PWID”), and knowing and intentional possession of heroin (“K&I”). Before the Traffic Division of the Municipal Court of Philadelphia, he was found guilty, in absentia, of the summary traffic offense. The Municipal Court’s jurisdiction was capped at criminal offenses punishable by imprisonment for a term of not more than five years; because of this, the Commonwealth pursued the drug offenses in the common pleas court. Appellant moved to dismiss, contending the prosecution was required to try all of the offenses simultaneously, per the compulsory joinder requirements of Section 110 of the Pennsylvania Crimes Code. The Commonwealth conceded it was foreclosed from pursuing the K&I charge, because that crime, like the traffic offense, fell within the Municipal Court’s jurisdiction. Nevertheless, the Commonwealth argued that PWID remained viable, since the Municipal Court had lacked jurisdiction over that offense. In this regard, the Commonwealth invoked Section 112(1) of the Crimes Code, which served as an exception to Section 110’s general prohibition. The Superior Court accepted this argument and affirmed with respect to PWID. The Pennsylvania Supreme Court reversed the Superior Court and remanded the matter for dismissal of the PWID charge: "the Commonwealth must generally assure that known offenses are consolidated at the common pleas level, when they arise out of a single criminal episode and occur in the same judicial district."
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