Com. v. Dunkowski, A.

CourtSuperior Court of Pennsylvania
DecidedMarch 9, 2026
Docket1507 EDA 2025
StatusUnpublished
AuthorPanella

This text of Com. v. Dunkowski, A. (Com. v. Dunkowski, A.) 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. Dunkowski, A., (Pa. Ct. App. 2026).

Opinion

J-S47003-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : ALBERT DUNKOWSKI : : Appellant : No. 1507 EDA 2025

Appeal from the PCRA Order Entered May 14, 2025 In the Court of Common Pleas of Bucks County Criminal Division at No(s): CP-09-CR-0000225-2020

BEFORE: PANELLA, P.J.E., OLSON, J., and BECK, J.

MEMORANDUM BY PANELLA, P.J.E.: FILED MARCH 9, 2026

Albert Dunkowski appeals pro se from the order of the Court of Common

Pleas of Bucks County dismissing his petition filed pursuant to the Post-

Conviction Relief Act (“PCRA”)1, without a hearing. Dunkowski argues that he

is entitled to relief on his claims of sufficiency of the evidence and ineffective

assistance of counsel. After careful review, we affirm the PCRA court’s order

dismissing his PCRA petition. However, for the first time on appeal, Dunkowski

argues his sentence was illegal because the sentencing court failed to consider

his recidivism risk reduction incentive (“RRRI”)2 eligibility. He is entitled to

relief on this claim. Therefore, we affirm the order dismissing the PCRA petition

and remand for the sentencing court to consider his RRRI eligibility.

____________________________________________

1 42 Pa.C.S.A. §§ 9541–9546.

2 61 Pa.C.S.A. §§ 4501–4512. J-S47003-25

This Court previously summarized the facts related to Dunkowski’s

underlying convictions. See Commonwealth v. Dunkowski, No. 1047 EDA

2022, 2023 WL 5129187 (Pa. Super. filed Aug. 10, 2023) (unpublished

memorandum).

In August 2019, police discovered Dunkowski and his wife inhabiting an automobile that was parked in the lot of the Woodbourn Train Station in Middletown Township. Upon arriving at the scene, officers observed Dunkowski lying face down in the grass. His wife was slumped over in the front passenger seat. Four children occupied the rear seat area of the vehicle. A cat was also living in the car. Officers noted that the vehicle was cluttered with trash, clothing, food, and debris. They also noticed the strong odor of bodily excretions, cigarettes, and rotting food. Due to the visibly poor physical condition of the children, the officers called Emergency Medical Services (“EMS”). EMS took protective custody of the children and transported them to the hospital.

The trial court offered the following review of the condition of the various children that were in the parental care of Dunkowski and his wife:

At [the hospital], treating physicians made the following assessments: N.D., who suffered from cerebral palsy, was thirteen years old and weighed about ninety pounds. She was nonverbal, had a feeding tube, and started to develop bedsores from remaining in the same position for a significant amount of time. J.D. was four years old and weighed about forty pounds. She was still in diapers as she was not yet trained to go to the bathroom on her own and she needed extensive dental work—a root canal, a crown, and three fillings. Female L.D. was five years old and weighed about forty-eight pounds. She was also still in diapers and needed nine root canals, nine crowns, one filling, and four teeth pulled. She had never been to school. Male L.D. was nine years old and weighed about sixty pounds. He had bilateral clubfeet ... as well as undescended testicles .... Both required procedures—several to improve Male L.D.’s clubfeet and one to surgically descend his testicles.

-2- J-S47003-25

Male L.D. also had such a severe, significant amount of dried, caked-on fecal matter on his diaper that when the doctor pulled it back, Male L.D.’s skin became raw and red. Dr. Torradas, the physician who treated the children, testified that, over the course of his lengthy career, he had never seen anything like what he saw on August 27, 2019.

That same day, [Dunkowski] and [his wife] spoke with Detective Brian Hyams (hereinafter “Detective Hyams”) and told him that none of the four children found were enrolled in school. Detective Hyams asked if they had any additional children and they provided the names of three more minors in their care. They relayed that one child, R.[D]., was staying with a friend at the time, but neither [Dunkowski] nor [his wife] could provide any contact information to get in touch with her. Authorities eventually found R.[D]. and discovered that she missed almost the entire 2018-2019 school year and had an abscess in her tooth that rendered her unable to chew and required significant dental surgery. Fortunately, R.D did not require immediate, emergency medical treatment.

Shortly thereafter, Detective Hyams discovered that [Dunkowski] and [his wife] had an eighth minor child—S.D.—they did not mention when previously asked. After some investigation, Detective Hyams located S.D. and [Dunkowski] agreed to “turn her over” to authorities in a McDonald’s parking lot. S.D. “appeared to be very thin, small, disheveled. Her hair was very short as if it wasn't growing, or falling out. Her eyes were puffy underneath. She was very, very quiet, almost like she was lethargic.” Doctors later determined she weighed about forty-two pounds. S.D. was unable to walk because her legs were bent in a seated position. She also still needed diapers—at thirteen years old—because [Dunkowski] and [his wife] never taught her how to use the bathroom. Authorities immediately took protective custody of S.D. and transported her to [the hospital] with the other children.

-3- J-S47003-25

Id. at **1-2 (quoting Trial Court Opinion, 6/23/22, at 2-4) (alterations in

original).

Dunkowski and his wife Christine were both charged with six counts of

endangering the welfare of children (“EWOC”).3 A consolidated jury trial

commenced on October 4, 2021. On the third day of trial, Dunkowski and his

wife failed to appear. The trial proceeded in abstentia. Dunkowski was

convicted of three counts of EWOC. For each count, he was sentenced to three

to seven years, consecutively, for an aggregate term of incarceration of 9 to

21 years.4 He filed a timely post-sentence motion which was denied.

Dunkowski filed a direct appeal, and this Court affirmed his judgment of

sentence. See Dunkowski, 2023 WL 5129187, at *8.

Thereafter,

On July 29, 2024, [Dunkowski] filed his first PCRA Petition, Th[e PCRA c]ourt appointed Stuart Wilder, Esquire to represent [Dunkowski], but on September 4, 2024, Mr. Wilder filed a Motion to Allow [Dunkowski] to Represent Himself in his Petition for PCRA Relief. The Petition stated that [Dunkowski] wished to represent himself, and after a hearing on the matter where [Dunkowski] advised th[e PCRA c]ourt of the same, th[e c]ourt granted [Dunkowski’s] Motion on December 18, 2024.

3 18 Pa.C.S.A. § 4304.

4 Dunkowski’s wife, Christine Dunkowski, was his co-defendant at trial. She

was convicted of the same charges and was sentenced to 8 to 21 years’ incarceration. Her conviction was affirmed on direct appeal. See Commonwealth v. Dunkowski, No. 1990 EDA 2022, 2023 WL 4397323 (Pa. Super. filed July 7, 2023) (unpublished memorandum). Her pro se appeal of the denial of her first PCRA petition is pending at docket number 1220 EDA 2025.

-4- J-S47003-25

On January 13, 2025, [Dunkowski] filed his pro se Amended Petition for Post Conviction Collateral Relief, wherein he challenged the sufficiency of the evidence presented at trial and alleged th[e sentencing c]ourt abused its discretion when imposing sentence and that his trial counsel was ineffective for: (1) not “moving for dismissal of the indictment” during said sentencing; (2) not interviewing his children in preparation for trial; and (3) not filing a successful direct appeal.

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Com. v. Dunkowski, A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-dunkowski-a-pasuperct-2026.