Com. v. Crum, M.

Superior Court of Pennsylvania·Decided August 20, 2026·No. 1332 WDA 2025·Unpublished·Bowes

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

:

v. :

:

:

MICHAEL P. CRUM :

:

Appellant : No. 1332 WDA 2025

Appeal from the Judgment of Sentence Entered August 7, 2025 In the Court of Common Pleas of Venango County Criminal Division at No(s): CP-61-CR-0000512-2022

BEFORE: BOWES, J., OLSON, J., and BENDER, P.J.E. MEMORANDUM BY BOWES, J.: FILED: August 20, 2026 Michael P. Crum appeals from the judgment of sentence of two and one-

half to seven years of imprisonment imposed after he entered a guilty plea to one count of driving under the influence of alcohol (“DUI”) – highest rate of alcohol, graded as a felony of the third degree.1 On October 8, 2021, Appellant was involved in an accident on Main Street in Venango County. A voluntary blood draw revealed that his blood alcohol content was above the legal limit of 0.08% at 0.2%. He was charged in the instant case with DUI – highest rate of alcohol. After being arraigned and released on bail, he failed to appear at his preliminary hearing in October 2022, which was held in absentia. Appellant absconded and could not be

1 A third or subsequent offense under § 3802(c) is graded as a felony of the third degree. See 75 Pa.C.S. § 3803(b) (4.1).

located until March 6, 2025, when he was apprehended, his bail was revoked, and he was placed in the Venango County Jail. On April 28, 2025, he entered his guilty plea in the instant matter.

At the plea hearing, the Commonwealth and Appellant presented the court with an agreement that Appellant would plead guilty to DUI and, in exchange, the Commonwealth would nolle pros the remaining charges and recommend a fourteen-month sentence.2 During the plea colloquy, the trial court asked Appellant: “Do you understand that, a recommendation by the Commonwealth is exactly that, a recommendation by the Commonwealth to the court and that I am not bound by or another sentencing judge is not bound to follow the recommended sentence?” See N.T. Plea Colloquy, 4/28/25, at 22. When Appellant answered in the affirmative, the court further inquired: “Okay and do you understand that if the court does not concur in the recommended sentence, that is not a basis for which to withdraw your plea, nor is it a grounds for purpose of appeal?” Id. After Appellant confirmed his understanding, the court accepted the plea and ordered a pre-sentence investigation (“PSI”).

2 When presented with the written plea agreement, the Honorable Justin S. Fleeger recognized that, while serving as District Attorney before Appellant absconded, he had personally signed Appellant’s plea offer. Judge Fleeger immediately directed that a new plea form be signed and advised Appellant that he would grant a motion for recusal. After a brief off-record discussion with counsel, Appellant declined to request recusal. Judge Fleeger nonetheless reassigned the case to the Honorable Matthew T. Kirtland for sentencing. See N.T. Plea Colloquy, 4/28/25, at 11.

Appellant appeared at his scheduled sentencing hearing with substitute counsel who sought a continuance so that previous counsel could be present at sentencing. The court granted the motion and reiterated to Appellant that the court “is not bound by the recommendation set forth in the plea agreement.” Order, 7/1/25.

At the subsequent sentencing hearing, the court confirmed that it had reviewed the PSI report. See N.T. Sentencing 8/7/25, at 10. Although the instant offense was chronologically Appellant’s fourth DUI, by the time he was apprehended and sentenced, it counted as his fifth DUI sentence. Appellant had been convicted of DUI in 2014 and 2019. He was charged with a DUI in Clarion County in January 2020, and that case remained unresolved for nearly four years. He ultimately pled guilty to the Clarion County offense in April 2024 and was sentenced to ninety days to two years of imprisonment.3 While a fugitive from justice in both Clarion and Venango Counties, Appellant committed another DUI offense in September 2022, this time in Butler County.4 (“Butler County DUI”). He pled guilty to this offense in March 2025 and was sentenced to six to twenty-three months of imprisonment, concurrent with his Clarion County sentence, with six months of credit for time served.

3 The publicly accessible court docket indicates that Appellant did not appear for the preliminary hearing. 4 Again, Appellant failed to appear for the preliminary hearing for this DUI as well.

Two days following his guilty plea in the Butler County DUI, he was apprehended on the instant charges.

The court noted that the offense gravity score was six and the prior record score was two. The court acknowledged that pursuant to 75 Pa.C.S. § 3804(c)(3)(i), Appellant’s offense carried a statutory minimum sentence of one year, and that the sentencing guidelines called for a standard-range minimum sentence of nine to sixteen months, plus or minus six months. Id. at 11. The Commonwealth, consistent with the plea agreement, recommended a prison sentence with a minimum term of fourteen months, i.e., two months in excess of the mandatory minimum, based upon Appellant’s violation of his bail conditions and the fact that this was his fifth DUI conviction. Id.

Defense counsel advised the court that Appellant had been accepted into the Erie City Mission Program to address his addiction and recovery. Id. at 12. During his allocution, Appellant requested the court allow him to complete that program concurrently with the fourteen-month sentence recommended by the Commonwealth. Id. at 13–14. In response, the court observed as follows:

[Y]ou had a point two BAC. There was an accident. The argument that you would be better suited to remain locally to get treatment here, the [c]ourt’s not going to keep you locally. This is a state sentence. In fairness, based on your prior history, your continued abuse of alcohol, your continued [choices] to drink and drive, the standard range is not appropriate either. With such a significantly high BAC with an accident, you haven’t stopped. Your words here today that you want an opportunity and that you know you need

to stop, there has been plenty of opportunity for you to stop. You could have stopped after your ARD, for instance.5 Which was for a DUI. Again, then you’ve actually had convictions and each time you would have received treatment. You would have received the care, but you didn’t stop. And then in this case, you were on bail for this case and then you abscond[ed]. You abscond for a long period of time. Again, that is not something that we should keep you here locally for. You have demonstrated that what we have here locally is not appropriate for you. So a state prison sentence is appropriate. I think on the continued nature of all of these, again, the standard range is not appropriate and I don’t believe the aggravated range is appropriate either in this case. I indicated on July 1, 2025 when you were before this [c]ourt that the [c]ourt was not bound by the recommendation set forth in the plea and therefore, I am not following it. I am not bound by it. I have given you that opportunity to have that conversation with counsel and yet, here we are.

Id. at 18-19. The court proceeded to sentence Appellant to a term of two and one-half to seven years of imprisonment. Id. at 19.

Appellant timely filed a post-sentence motion requesting that his “sentence be modified to reflect the sentence recommendation as provided within the plea offer.” See Post Sentence Motion, 8/7/25, at 2. The court denied the motion. Appellant then filed a timely notice of appeal and complied with the court’s order to file a concise statement of errors pursuant to Pa.R.A.P. 1925(b). The trial court filed a Rule 1925(a) opinion in response.

Appellant presents us with the following issue:

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Com. v. Crum, M., (Pa. Ct. App. 2026).

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