Com. v. Ayala, J.

CourtSuperior Court of Pennsylvania
DecidedJuly 25, 2025
Docket1670 EDA 2024
StatusUnpublished

This text of Com. v. Ayala, J. (Com. v. Ayala, J.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Com. v. Ayala, J., (Pa. Ct. App. 2025).

Opinion

J-S14028-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : JOSE AYALA : : Appellant : No. 1670 EDA 2024

Appeal from the Judgment of Sentence Entered May 23, 2024 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0005481-2013

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : JOSE AYALA : : Appellant : No. 1671 EDA 2024

Appeal from the Judgment of Sentence Entered May 23, 2024 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): MC-51-CR-0030769-2018

BEFORE: DUBOW, J., BECK, J., and STEVENS, P.J.E.*

MEMORANDUM BY BECK, J.:

Jose Ayala (“Ayala”) appeals from the judgment of sentence imposed by

the Philadelphia County of Common Pleas (“trial court”) following the

revocation of his probation at docket number MC-51-CR-0030769-2018

____________________________________________

* Former Justice specially assigned to the Superior Court. J-S14028-25

(“30769-2018”).1 Ayala contends that the Commonwealth introduced

insufficient evidence to establish that he was in technical violation of the terms

of his probation at docket number 30769-2018. Upon review, we vacate

Ayala’s judgment of sentence and remand for the trial court to conduct a new

violation of probation hearing in accordance with this decision.

The trial court oversees Ayala’s probation at six cases dating back to

2013.2 His repeat drug offenses and probation violations have extended his

original terms of probation into a tangled web of interconnecting cases. At

docket number 30769-2018, the case relevant to the instant appeal, Ayala

pleaded guilty to possession of a controlled substance while he was serving

terms of probation at other dockets. On March 13, 2019, Ayala received his

initial sentence of twelve months of probation supervised by the county

probation department. Had Ayala served this term from the outset, he would

have completed it by March 13, 2020. However, according to the docket for

case number 30769-2018, on four occasions, the trial court found probable

1 Ayala also filed a notice of appeal at docket number CP-51-CR-0005481- 2013 (“5481-2013”), but he is no longer pursuing an appellate challenge pertaining to this docket. See Ayala’s Brief at 3.

2 The other five cases are docketed at CP-51-CR-0004110-2013 (“4110- 2013”), 5481-2013, CP-51-CR-0009590-2014 (“9590-2014”), CP-51-CR- 0006722-2016 (“6722-2016”), and MC-51-CR-0013007-2019 (“13007- 2019”).

-2- J-S14028-25

cause to believe that Ayala violated his probation following Gagnon I hearings

and lodged detainers pending Gagnon II hearings.3

The trial court lodged the first detainer on May 28, 2019. Gagnon I

Hearing Disposition, 5/28/2019, at 1. The following month, the trial court

granted a motion to continue probation and lifted the detainer. Order

Continuing Probation, 8/29/2019, at 1.

The court lodged a second detainer on November 6, 2020. Gagnon I

Hearing Disposition, 11/6/2020, at 1. Presumably, this detainer related to

Ayala’s November 1, 2020 arrest and subsequent May 2021 charges of

possession of a controlled substance at docket number CP-51-CR-0004223-

2021 (“4223-2021”).4 On June 22, 2021, the trial court lifted the second

detainer lodged at docket number 30769-2018 and continued the Gagnon II

hearing “for status of open bill.” Trial Court Order, 6/22/2021, at 1

(capitalization modified). On October 27, 2021, the trial court issued a bench

warrant and wanted cards because Ayala failed to appear at the Gagnon II

3 See Gagnon v. Scarpelli, 411 U.S. 778 (1973); see also Commonwealth

v. Ferguson, 761 A.2d 613 (Pa. Super. 2000) (explaining that when a probationer is detained based on an alleged probation violation, due process requires a Gagnon I pre-revocation hearing to determine whether there is probable cause that the probationer committed a violation, followed by a second more comprehensive Gagnon II revocation hearing wherein trial court determines whether to revoke probationer’s probation).

4 We derive the facts regarding the procedural history of docket number 4223- 2021 from the public docket sheet, of which we take judicial notice. See Pa.R.E. 201(b)(2), (c)(1).

-3- J-S14028-25

hearing and had no contact with the probation department. Bench Warrant

Probation Violation, 10/27/2021, at 1.

The trial court lodged a third detainer on November 30, 2021. Gagnon

I Hearing Disposition, 11/30/2021, at 1. It later lifted the third detainer on

April 28, 2022, when it ordered the sheriff to transport Ayala to the “FIR

facility” when a bed became available. Order Lifting Detainer, 4/28/2022, at

1.5 On July 14, 2022, however, Ayala failed to appear at the Gagnon II

hearing, prompting the issuance of a second bench warrant and wanted cards.

Bench Warrant Probation Violation, 7/14/2022, at 1.

No further activity occurred until a Gagnon I hearing on January 17,

2024, wherein the court lifted the bench warrant and lodged a detainer,

incarcerating Ayala pending a Gagnon II hearing. Gagnon I Hearing

Disposition, 1/17/2024, at 1. Meanwhile, on January 23, 2024, Ayala entered

a guilty plea at case number 4223-2021.

The Commonwealth filed a Gagnon II summary report prior to the

hearing, asserting that Ayala was in direct violation based upon the conviction

at 4223-2021 as well as a technical violation for failure to report. Gagnon II

Summary, 3/1/2024, at 2 (numbering supplied). The report also referred to

a potential direct violation for an arrest in January 2024. Id. Regarding the

technical violation, the summary stated that Ayala was “in technical violation

5 Presumably, FIR stands for Forensic Intensive Recovery facility.

-4- J-S14028-25

for absconding and being placed on Wanted Cards on two different occasions,

incurring three new arrests and failing to appear at two VOP's [sic] on

10/27/2021 and 7/14/2022. [] Ayala has NEVER reported to the Probation

Department during the four years that he has been under probation

supervision.” Id. at 3.

On March 13, 2024, the trial court conducted a brief Gagnon II hearing

regarding Ayala’s six probationary cases, including case number 30769-2018.

To illustrate the hearing’s brevity, we have replicated the notes of testimony

from the hearing in their entirety following the calling of the case and entry of

counsels’ appearances:

[Trial Court]: This is a direct violation; is that correct?

[Prosecutor]: That’s correct.

[Defense counsel]: That’s my understanding, Your Honor. It would be my request for a [presentence investigation (“PSI”)] and a deferred sentencing date. He does have [six] dockets and I need time to calculate all of his exposure and the amount of time credit that he has and I would like to see what the PSI says.

[Trial court]: Without a hearing first I have not found him in violation.

[Defense counsel]: We’re not contesting the direct.

[Prosecutor]: The Commonwealth has no objection to that, Your Honor.

[Trial court]: All right. So I find the defendant in direct violation. Give me a date for sentencing long enough for him to get a PSI. Do you need a mental health report?

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Related

Morrissey v. Brewer
408 U.S. 471 (Supreme Court, 1972)
Gagnon v. Scarpelli
411 U.S. 778 (Supreme Court, 1973)
Commonwealth v. Mullins
918 A.2d 82 (Supreme Court of Pennsylvania, 2007)
Commonwealth v. Brown
469 A.2d 1371 (Supreme Court of Pennsylvania, 1983)
Commonwealth v. Ortega
995 A.2d 879 (Superior Court of Pennsylvania, 2010)
Commonwealth v. Ferguson
761 A.2d 613 (Superior Court of Pennsylvania, 2000)
Commonwealth v. Allshouse
969 A.2d 1236 (Superior Court of Pennsylvania, 2009)
Commonwealth v. Kates
305 A.2d 701 (Supreme Court of Pennsylvania, 1973)
Commonwealth v. Colon
102 A.3d 1033 (Superior Court of Pennsylvania, 2014)
Commonwealth v. Heilman
876 A.2d 1021 (Superior Court of Pennsylvania, 2005)
Commonwealth v. Cartrette
83 A.3d 1030 (Superior Court of Pennsylvania, 2013)

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Com. v. Ayala, J., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-ayala-j-pasuperct-2025.