Com. v. Walsh, E.

2026 Pa. Super. 47
CourtSuperior Court of Pennsylvania
DecidedMarch 16, 2026
Docket1012 EDA 2025
StatusPublished
AuthorNeuman

This text of 2026 Pa. Super. 47 (Com. v. Walsh, E.) 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. Walsh, E., 2026 Pa. Super. 47 (Pa. Ct. App. 2026).

Opinion

J-S04039-26 2026 PA Super 47

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : EDWARD E. WALSH, JR. : No. 1012 EDA 2025

Appeal from the Order Entered March 13, 2025 In the Court of Common Pleas of Delaware County Criminal Division at No(s): CP-23-CR-0000351-2024

BEFORE: LAZARUS, P.J., STABILE, J., and NEUMAN, J.

OPINION BY NEUMAN, J.: FILED MARCH 16, 2026

The Commonwealth, as the appellant, appeals from the trial court’s

March 13, 2025 order granting Edward E. Walsh, Jr.’s (“Walsh”) motion to

dismiss a charge of driving under the influence (DUI) under 18 Pa.C.S. §

3802(d)(2). After careful review, we reverse in part, affirm in part, and

remand for further proceedings.

Walsh was charged with the above-stated DUI offense, as well as several

summary traffic violations, based on a traffic stop conducted in October of

2023. At Walsh’s preliminary hearing on January 18, 2024,

the arresting police officer, James Kelso, testified concerning his encounter with [Walsh] around 9:10 PM on October 11, 2023. He observed an automobile occupying two lanes of travel and later swerving back-and-forth across a single lane. After stopping the vehicle, Officer Kelso noted the driver’s ([Walsh’s]) constricted pupils (despite the prevailing low light environment), episodic displays of irritability and agitation, exaggerated reflexes[,] as well as [Walsh’s] difficulty in speaking. [Walsh] denied the [o]fficer’s request that he participate in field sobriety testing. Officer Kelso believed [Walsh] was using drugs which affected his driving and arrested [Walsh] for DUI. While it is not clear as to J-S04039-26

the order of events, the officer also testified that he found “numerous bottles of kratom, some open, some unopened, as well as a liquid on the driver’s side floorboard consistent with the kratom in the bottle,” [N.T. Preliminary Hearing,] 1/18/24[,] at 8. [Walsh] was taken to a local hospital where he submitted to chemical blood testing. The argument for maintaining the DUI charge rested upon [Walsh’s] use of kratom2 and caffeine and the effect these substances had on his ability to safely operate a motor vehicle. 2 “Kratom” commonly refers to an herbal substance that can

produce opioid- and stimulant-like effects. See https://nida.nih.gov/research-topics/kratom (last visited 4/25/25).

The test results, according to the [o]fficer, revealed the presence of mitragynine[1] and caffeine. A lab analysis was presented at the preliminary hearing; however, those documents were not presented to this court for consideration.[2] Officer Kelso offered ____________________________________________

1 Mitragynine is “the principal psychoactive indole alkaloid C 23H30N2O4 that is found in kratom and that binds as an agonist to certain opioid receptors to produce effects (such as analgesia) similar to that of opioids.” Mitragynine, Merriam-Webster Dictionary, https://www.merriam- webster.com/dictionary/mitragynine (last visited Feb. 13, 2026).

2 The Honorable Deborah A. Krull of the Court of Common Pleas of Delaware

County noted, at the outset of her opinion, that Walsh’s case was

before [her] after a local reassignment of jurists to different divisions. Previously, the pending [m]otion [to dismiss] … was submitted to [the Honorable] Anthony D. Scanlon. He was provided a copy of the transcript from the preliminary hearing and scheduled a hearing where only argument was presented. These materials were passed along as the record. We recognize that our handling of this [h]abeas [m]otion is as a court de novo. For that reason, the Commonwealth and defense counsel were given an opportunity to agree to submission of whatever portions of the previous record they wished and/or present such evidence as was deemed appropriate. Upon reassignment, the Notes of Testimony from both the preliminary hearing and the argument before Judge Scanlon formed the basis for decision-making.

Trial Court Opinion (TCO), 5/29/25, at 1.

-2- J-S04039-26

significant information regarding kratom at the preliminary hearing. However, we note that he was not qualified to testify as an expert witness or even as an officer with specialized training or experience with what our legislature has defined (and what is referenced infra) as “drugs” at the preliminary hearing.

TCO at 2.

At the close of the preliminary hearing, the magisterial district judge

found the Commonwealth had established a prima facie case and bound all

charges to the Court of Common Pleas. See N.T. Preliminary Hearing at 17.

On December 13, 2024, Walsh filed a “Motion to Quash the Bills of

Information.” Therein, he averred:

4. The Commonwealth failed to establish a prima facie case on the charges in this matter. According to the notes of testimony from the preliminary hearing held on January 18, 2024, a blood draw was performed wherein the only substances found in [Walsh’s] blood were caffeine and kratom, neither of which are a controlled substance. See N.T. [Preliminary Hearing] at … 8, 11-12. A copy of the preliminary hearing transcript from January 18, 2024 … shall be provided to this Honorable Court and the Commonwealth separate from this motion.

5. To establish a prima facie case for DUI as charged, the Commonwealth must show three elements: “1) that the defendant drove; 2) while under the influence of a controlled substance; and 3) to a degree that impairs the defendant’s ability to drive safely.” Commonwealth v. Spence, [290 A.3d 301, 309 (Pa. Super. 2023)] (citing Commonwealth v. Griffith, … 32 A.3d 1231, 1238 ([Pa.] 2011))1 (emphasis added).2 1 Although both the Spence and Griffith Courts are addressing separate appeals post-trial, the elements of the offense remain the same whether the burden is prima facie or beyond a reasonable doubt and is thus applicable to the instant matter. 2 Counsel for [Walsh] notes that the statute in question[,]

75 Pa.C.S. § 3802(d)(2)[,] as written states[,] “[t]he individual is under the influence of a drug or combination of drugs to a degree which impairs the individual’s ability to

-3- J-S04039-26

safely drive, operate or be in actual physical control of the movement of the vehicle.” However, the Spence and Griffith Courts specifically describe the elements of the offense to include the Commonwealth’s need to show that the substance in question is a controlled substance, apparently recognizing the severe implications of charging those individuals under the influence of non-controlled substances with DUI. It is undisputed through the testimony and lab results provided at the preliminary hearing on January 18, 2024[,] that [Walsh] was not under the influence of a controlled substance. As such, the Commonwealth has not sustained [its] burden and the current case before this Honorable Court must be quashed and dismissed.

6. The charges against [Walsh] should be quashed and dismissed as no evidence was presented at the preliminary hearing necessary to establish a prima facie case and hold [Walsh] for trial.

7. [Walsh] respectfully requests that this Honorable Court quash the bills of information against him and dismiss all charges.

Motion to Quash, 12/13/24, at 1-2 (unnumbered; unnecessary capitalization

and italicized emphasis omitted; some bolded emphasis in original, some

added).

On February 19, 2025,3 Judge Scanlon conducted a hearing at which the

parties presented arguments on Walsh’s motion. First, Walsh reiterated his

arguments that Spence and Griffith specifically declared “the Commonwealth

has to show that the [d]efendant is under the influence of a controlled

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Cite This Page — Counsel Stack

Bluebook (online)
2026 Pa. Super. 47, Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-walsh-e-pasuperct-2026.