Com. v. Frehafer, R.

CourtSuperior Court of Pennsylvania
DecidedJuly 1, 2025
Docket1055 MDA 2024
StatusUnpublished

This text of Com. v. Frehafer, R. (Com. v. Frehafer, R.) 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. Frehafer, R., (Pa. Ct. App. 2025).

Opinion

J-A07040-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : RICHARD ALLEN FREHAFER : : Appellant : No. 1055 MDA 2024

Appeal from the Order Entered July 11, 2024 In the Court of Common Pleas of Dauphin County Criminal Division at No: CP-22-CR-0003284-2021

BEFORE: BOWES, J., OLSON, J., and STABILE, J.

MEMORANDUM BY STABILE, J.: FILED: JULY 1, 2025

Appellant, Richard Allen Frehafer, challenges an order of the Court of

Common Pleas of Dauphin County (trial court), denying as untimely filed his

pro se “Motion to Dismiss the Unconstitutional Conviction, Sentence, and

Requirement to Register as a Sex Offender” (the Motion). Finding that

Appellant’s Motion was timely, but that his registration and reporting

requirements were lawfully imposed, we affirm the order on review. On

remand, however, we direct the trial court to clarify for Appellant the specific

statutory provisions in which those requirements are enumerated.

The underlying offenses in this case took place on October 22, 2007.

Appellant was charged with rape, sexual assault, aggravated indecent assault,

indecent assault, unlawful restraint, and false imprisonment. Following a jury

trial held on May 21, 2009, he was found guilty of the above crimes. Appellant

was then sentenced on October 5, 2009, to an aggregate prison term of 7-15 J-A07040-25

years, followed by two years of probation. Appellant received notice on

October 15, 2009, that he would be subject to lifetime registration

requirements as a sex offender pursuant to the version of Megan’s Law III

then in effect at the time the subject offenses took place (42 Pa.C.S.A. §

9795.1(b)).1

On July 14, 2021, after serving the incarcerative portion of his sentence,

Appellant’s probation officer discovered that he had failed to timely notify the

Pennsylvania State Police (the PSP) of a change in residence and employment

in the prior month. Due to this untimely reporting, on July 14, 2021, Appellant

was arrested and charged under section 18 Pa.C.S.A. § 4915.2(a)(1) of

Subchapter I of the Sexual Offender Registration and Notification Act (SORNA

II), with failure to report the changes in circumstances within three days to

the PSP. The offense was graded in SORNA II as a second-degree felony.

“SORNA I” had become effective on December 20, 2012, replacing

Megan’s Law III on that date. On June 12, 2018, SORNA I was then replaced

with SORNA II to remedy the former version’s unconstitutional requirements

____________________________________________

1 The requirements applicable to Appellant, and the punishments for failing to

comply with them, were outlined in the version of section 4915(c) of Megan’s Law III that was in force from January 1, 2007, until December 19, 2011. Effective January 1, 2017, an amendment to section 4915 of Megan’s Law III changed the grading of first-time violations of the offense. As of the date of Appellant’s underlying sexual offenses, the crime of failing to timely register, for an individual subject to lifetime registration under Megan’s Law III, was punishable as a second-degree felony. See 18 Pa.C.S.A. § 4915(c)(2), Act No. 2006–178, S.B. No. 944, effective Jan. 1, 2007. Prior to that amendment, the offense was graded as a second-degree misdemeanor. See Commonwealth v. Derhammer, 173 A.3d 723, 726 (Pa. 2017).

-2- J-A07040-25

for offenders whose crimes preceded the effective date of SORNA I.

Subchapter H of SORNA II governs crimes committed on or after December

20, 2012, whereas, Subchapter I of SORNA II applies to crimes committed

after April 22, 1996, but before December 20, 2012.

Section 4915.2(c), in Subchapter I of SORNA II, now applies to an

“individual [like Appellant,] who was required to register with the [PSP] under

a former sexual offender registration law of this Commonwealth on or after

April 22, 1996, but before December 20, 2012, and whose period of

registration has not expired.” 18 Pa.C.S.A. § 4915.2(f)(2). The offense of

failing to report is graded under SORNA II as a second-degree felony, carrying

a maximum penalty of 10 years in prison. See 18 Pa.C.S.A. § 4915.2(c)(2).

Appellant entered a counseled guilty plea to that count on November 29, 2021.

On February 17, 2022, the trial court imposed a prison term of 1.5-3

years as to the offense of failing to register. The trial court advised Appellant

at sentencing that he was designated as a “Tier III” sex offender under SORNA

II, subjecting him to the statute’s lifetime registration requirements. He was

also advised that he would have 10 days from the date of the forthcoming

sentencing to file any post-trial motions, and that he had 30 days from the

date of sentencing, or 30 days from the date a motion to modify sentence was

ruled upon, to file an appeal. Appellant did not file any post-sentence motions

within 10 days of the date of his sentencing; nor did he file a timely appeal

from a motion to modify his sentence, or from the judgment of sentence.

-3- J-A07040-25

On April 3, 2024, Appellant filed his pro se Motion, arguing that his

conviction for failing to register, and his registration requirements under

SORNA II, must be vacated on three main grounds:

(a) The SORNA II registration requirements imposed upon him retroactively violated the ex post facto clauses of the United States and Pennsylvania Constitution because failing to register under Megan’s Law III was only punishable as a second-degree misdemeanor;

(b) The conviction in 2021 for failing to register was “void” because after Megan’s Law III expired in 2012, the trial court had no authority to impose any new registration requirements under SORNA II; and

(c) The imposition of SORNA II’s mandatory, irrebuttable presumption of likely recidivism violated his due process rights by impairing his right to reputation, as protected by Article I, Section 1 of the Pennsylvania Constitution.

Appellant’s Motion, 4/3/2024, at 2-22 (arguments rephrased).2

The trial court declined to entertain the merits of Appellant’s Motion,

instead entering an order on July 11, 2024, finding it to be untimely filed

whether construed as a post-sentence motion or a petition for collateral relief

under the Post Conviction Relief Act (PCRA), 42 Pa.C.S.A. §§ 9541-9546.

2 Appellant also raised an additional issue which he subsequently abandoned

in the present appeal. He contended that the charging document was defective because it did not specify the manner in which he failed to report to the Pennsylvania State Police. See Appellant’s Motion, 4/3/2024, at 17-19.

-4- J-A07040-25

Appellant timely appealed from that order, and in his brief, he reiterates the

above grounds asserted in his Motion. See Appellant’s Brief, at iv.3

As to the timeliness of his underlying request for relief before the trial

court, Appellant argues that his Motion should be construed as a PCRA petition

that was filed within one year from the date his judgment of sentence became

final. He argues in the alternative that the trial court had no “power and

authority” to render judgment or impose registration requirements under

SORNA II, making the judgment of sentence an illegal nullity which may be

challenged “at any time.” See Appellant’s Brief, at 16-18. Since the

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