Com. v. Sutton, K.

CourtSuperior Court of Pennsylvania
DecidedJune 20, 2025
Docket1922 EDA 2024
StatusUnpublished

This text of Com. v. Sutton, K. (Com. v. Sutton, K.) 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. Sutton, K., (Pa. Ct. App. 2025).

Opinion

J-A10021-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : KARIM SUTTON : No. 1922 EDA 2024

Appeal from the Order Entered June 28, 2024 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0001651-2024

BEFORE: PANELLA, P.J.E., BECK, J., and FORD ELLIOTT, P.J.E. *

MEMORANDUM BY BECK, J.: FILED JUNE 20, 2025

The Commonwealth appeals the order entered by the Philadelphia

County Court of Common Pleas (“trial court”) granting the motion to dismiss

filed by Karim Sutton (“Sutton”) pursuant to Rule 600 of the Pennsylvania

Rules of Criminal Procedure.1 Because the pre-arrest delay was caused by the

Commonwealth’s failure to exercise due diligence as required by Rule 600, we

affirm.

On December 15, 2021, the Commonwealth filed a criminal complaint

charging Sutton with aggravated assault2 and related charges in connection ____________________________________________

* Retired Senior Judge assigned to the Superior Court.

1 In general, Rule 600 requires the Commonwealth to bring a defendant to trial within 365 days of the filing of the criminal complaint. See Pa.R.Crim.P. 600(A)(2)(a).

2 18 Pa.C.S. § 2702(a)(1). J-A10021-25

with a shooting that struck a victim’s leg on December 8, 2021, in Philadelphia.

More than two years later, on February 20, 2024, police arrested Sutton on

those charges. After a preliminary hearing on March 7, 2024, the charges

were bound over for trial.

On May 17, 2024, Sutton filed a motion to dismiss pursuant to Rule 600

based on the delay between the filing of the criminal complaint and his arrest.

The trial court held a hearing on the motion on May 21, 2024, at which the

Commonwealth presented evidence of its efforts to locate and arrest Sutton.

After the parties filed briefs, the trial court issued its findings of fact and

conclusions of law and granted Sutton’s motion to dismiss on June 28, 2024.

The Commonwealth timely appealed and now raises one issue for our review:

Did the lower court err by dismissing all charges under Rule 600, where the Commonwealth established that it was duly diligent in attempting to apprehend [Sutton] between the filing of the criminal complaint and his arrest, and where fewer than 365 raw calendar days elapsed between [his] arrest and the dismissal of the charges?

Commonwealth’s Brief at 4.

“We review a trial court’s Rule 600 ruling for an abuse of discretion[.]”

Commonwealth v. Rice, 331 A.3d 5, 9 (Pa. Super. 2025) (citation omitted).

An abuse of discretion “is not merely an error of judgment” but occurs when

“the evidence of record establishes that in reaching a conclusion the law is

overridden or misapplied or the judgment exercised is manifestly

unreasonable, or the result of partiality, prejudice, bias, or ill will[.]” Id.

(citation and quotation marks omitted). “[W]e must view the facts in the light

-2- J-A10021-25

most favorable to the prevailing party and limit our scope of review to the

evidence on the record of the Rule 600 evidentiary hearing, and the findings

of the trial court.” Id. (citation and quotation marks omitted).

Rule 600 generally requires the Commonwealth to bring a defendant to

trial within 365 days of the filing of the criminal complaint. See Pa.R.Crim.P.

600(A)(2)(a).

In a Rule 600 analysis, the “mechanical run date” is 365 days after the complaint was filed. The “adjusted run date” is then calculated by adding any time that is “excluded from the computation” under Rule 600(C)(1). If a defendant is not brought to trial by the adjusted run date, the case is dismissed.

Rice, 331 A.3d at 9 (citation omitted). To determine the adjusted run date,

Rule 600(C)(1) provides that

periods of delay at any stage of the proceedings caused by the Commonwealth when the Commonwealth has failed to exercise due diligence shall be included in the computation of time within which trial must commence. Any other delay shall be excluded from the computation.

Pa.R.Crim.P. 600(C)(1).

If the Commonwealth fails to try the defendant within the prescribed

period, the defendant may, at any time before trial, “file a written motion

requesting that the charges be dismissed with prejudice on the ground that

this rule has been violated.” Pa.R.Crim.P. 600(D)(1). “[W]hen a Rule 600

motion is filed before trial commences, Rule 600 is examined as of the date

the Rule 600 motion is filed, since logically, a trial date cannot be used as no

-3- J-A10021-25

trial has commenced.” Rice, 331 A.3d at 10 (citation and quotation marks

omitted).

“It is the Commonwealth’s burden to demonstrate due diligence by a

preponderance of the evidence to avail itself of an exclusion under Rule 600.”

Commonwealth v. Graves, 328 A.3d 1005, 1009 (Pa. Super. 2024) (citing

Commonwealth v. Selenski, 994 A.2d 1083, 1089 (Pa. 2010)). “Due

diligence is fact-specific, to be determined case-by-case; it does not require

perfect vigilance and punctilious care, but merely a showing the

Commonwealth has put forth a reasonable effort.” Selenski, 994 A.2d at

1089.

The record reflects that at the Rule 600 hearing, the Commonwealth

presented the testimony of City of Philadelphia Detective Nicholas Martella

and Police Officer Timothy McGinn. The trial court also admitted four

Commonwealth, and one defense, exhibits, including a police log which

documented attempts to locate and apprehend Sutton.

The trial court made the following findings of fact:

On December 8, 2021, Detective [] Martella was assigned to investigate a nonfatal shooting near the intersection of 23 rd and Mifflin Streets in Philadelphia. He determined the identity of the perpetrator based on identifications made by Sergeant Jayson Troccoli, who recognized Sutton from his days on patrol in the first district, and Aquanetta Joyce (“Joyce”), a lifelong friend of Sutton. Following a search of the CLEAR [FN]2 and Bureau of Motor Vehicles databases, and corroborated by Joyce, Detective Martella determined Sutton’s address … in Philadelphia and obtained a search warrant for the property. On December 14, 2021, he executed the search warrant, but Sutton was not present. Sutton’s sister, whose name was indicated on the property search,

-4- J-A10021-25

was there and spoke with detectives, telling them that Sutton was not home. Detective Martella spoke with her about the case, left a copy of the search warrant, and recovered several of Sutton’s belongings from the basement of the home, where he appeared to be living, including his driver’s license and clothing from the shooting. The next day, on December 15, 2021, Detective Martella drafted a criminal complaint and obtained an arrest warrant for Sutton. N.T., 5/21/[20]24[,] at 11-15.

[FN]2 CLEAR Investigation Software is a research tool used by

law enforcement that leverages public records to locate individuals, identify phone, address, and vehicle records, and perform advanced web searches.

Detective Martella drove through the neighborhood looking for Sutton, created and sent out a patrol alert with Sutton’s picture, which was emailed citywide to law enforcement agencies on December 17, 2021, and reconnected with Joyce to determine if she knew his whereabouts.

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Related

Commonwealth v. Mitchell
372 A.2d 826 (Supreme Court of Pennsylvania, 1977)
Commonwealth v. Newman
555 A.2d 151 (Supreme Court of Pennsylvania, 1989)
Commonwealth v. Ingram
591 A.2d 734 (Superior Court of Pennsylvania, 1991)
Commonwealth v. SELENSKI
994 A.2d 1083 (Supreme Court of Pennsylvania, 2010)
Commonwealth v. Dorsey
440 A.2d 619 (Superior Court of Pennsylvania, 1982)
Commonwealth v. Collins
404 A.2d 1320 (Superior Court of Pennsylvania, 1979)
Commonwealth v. Barbour, D., Aplt.
189 A.3d 944 (Supreme Court of Pennsylvania, 2018)
Commonwealth v. Webb
420 A.2d 703 (Superior Court of Pennsylvania, 1980)
Commonwealth v. Branch
486 A.2d 460 (Superior Court of Pennsylvania, 1984)

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