Com. v. Weiss, E.

CourtSuperior Court of Pennsylvania
DecidedMarch 12, 2026
Docket1001 EDA 2025
StatusUnpublished
AuthorStabile

This text of Com. v. Weiss, E. (Com. v. Weiss, 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. Weiss, E., (Pa. Ct. App. 2026).

Opinion

J-S39008-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : EUGENE EDWARD WEISS, JR. : : Appellant : No. 1001 EDA 2025

Appeal from the Judgment of Sentence Entered March 31, 2025 In the Court of Common Pleas of Chester County Criminal Division at No: CP-15-CR-0002545-2021

BEFORE: STABILE, J., NICHOLS, J., and SULLIVAN, J.

MEMORANDUM BY STABILE, J.: FILED MARCH 12, 2026

Appellant, Eugene Edward Weiss, appeals from the judgment of

sentence entered in the Court of Common Pleas of Chester County on March

31, 2025. Upon review, we remand for further proceedings.

The trial court summarized the relevant background as follows.

[Appellant] was arrested and charged with numerous counts of rape, assault and involuntary deviate sexual intercourse committed against his own adopted minor daughter between 1993 and 2001. Twenty-four charges were listed on the verdict slip that was sent out with the jury for their deliberation. Ultimately, the jury convicted [Appellant] of nine (9) separate offenses. On October 18, 2023, the [trial court] sentenced [Appellant] consecutively to the mandatories for each conviction. His total sentence amounted to a minimum of thirty-five (35) years and a maximum of seventy (70) years confinement in a state correctional facility[.]

Trial Court Order, 3/31/25, at 2, n.1 (emphasis removed).

Post-trial motions were timely filed by [Appellant]. The post-trial motion raised two key issues. The first was regarding the length J-S39008-25

of the sentence imposed[,] which was promptly denied after argument. The second issue . . . involved allegations of prosecutorial misconduct as the prosecutor was perceived by Appellant to have been emotional in his closing argument. As this court specifically failed to address that issue, an uncontested petition for nunc pro tunc relief was submitted and a hearing was held on March 24, 2025. [The trial] court denied the underlying request for relief on or about March 31, 2025. Thereafter, on April 17, 2025 a notice of appeal was filed.

Trial Court Opinion, 5/16/25, at 1-2 (emphasis added).

Timeliness

Before we may reach the merits of this appeal, we must address the

timeliness of the instant appeal. See, e.g., Commonwealth v. Valentine,

928 A.2d 346, 349 (Pa. Super. 2007) (timeliness of appeal can be raised sua

sponte because issue is jurisdictional). We hold that the appeal is timely.

As noted above, Appellant’s judgment of sentence was imposed on

October 18, 2023. On Monday, October 30, 2023, Appellant filed timely post-

sentence motions seeking (i) reconsideration of his sentence and (ii) an

evidentiary hearing regarding alleged prosecutorial misconduct during closing

arguments.

On October 31, 2023, the trial court entered an “order granting motion

for reconsideration of sentence – a new sentencing hearing is to be

scheduled.” On November 15, 2023, the trial court entered an order to

continue resentencing. On March 13, 2024, more than 120 days after the

filing of post-sentence motions, the trial court entered an order denying

Appellant’s motion for reconsideration of sentence.

-2- J-S39008-25

None of these orders mentioned Appellant’s request for an evidentiary

hearing on prosecutorial misconduct.

Nearly seven months later, on October 3, 2024, Appellant filed a “Motion

for Nunc Pro Tunc” relief pointing out that the court had never decided his

post-sentence motion alleging prosecutorial misconduct. See Appellant’s

Motion, 10/3/24, at 1-2. The Commonwealth did not oppose this motion.

Another five months passed. On March 13, 2025, the court granted an

evidentiary hearing concerning the alleged prosecutorial misconduct. 1 On

March 31, 2025, following a hearing, the court denied Appellant’s nunc pro

tunc motion.

The Rules of Criminal Procedure provide that the trial court shall decide

post-sentence motions within 120 days after the date of filing. 2 Pa.R.Crim.P.

720(B)(3)(a). If the court fails to decide the motion within the 120-day

period, the motion shall be deemed denied by operation of law. Id. When

____________________________________________

1 As shown above, the trial court noted:

As this court specifically failed to address that issue [i.e., Appellant’s request for an evidentiary hearing on the alleged Commonwealth’s misconduct], an uncontested petition for nunc pro tunc relief was submitted and a hearing was held on March 24, 2025. [The trial] court denied the underlying request for relief on or about March 31, 2025.

Trial Court Opinion, 5/16/25, at 1-2.

2 Upon motion of the defendant, and for good cause shown, the court may grant one thirty-day extension of the 120-day period. Pa.R.Crim.P. 720(B)(3)(c). Appellant did not request any such extension in this case.

-3- J-S39008-25

the motion is denied by operation of law, the clerk of courts shall enter an

order denying the motion on behalf of the court, Pa.R.Crim.P. 720(B)(3)(c),

and the appeal must be filed within thirty days after entry of this order.

Pa.R.Crim.P. 720(A)(2)(b).

Our detailed analysis in Commonwealth v. Martinez, 141 A.3d 485

(Pa. Super. 2016), makes clear that the court must “resolve,” i.e., fully decide,

all post-sentence motions within the 120-day period. Id. at 489-90.3 If the

court fails to resolve post-sentence motions within the 120-day period, they

are denied by operation of law. Pa.R.Crim.P. 720(B)(3)(a).

Since Appellant filed timely post-sentence motions on October 30, 2023,

the 120-day deadline for resolving these motions was February 27, 2024. The

trial court failed to resolve Appellant’s post-sentence motions within the 120-

day period. Thus, Appellant’s post-sentence motions were denied by

operation of law.4 Both the March 13, 2024, order denying Appellant’s post-

sentence motion for modification of sentence and the March 31, 2025, order

denying Appellant’s post-sentence motion alleging prosecutorial misconduct ____________________________________________

3 Martinez held that Pa.R.Crim.P. 721 requires the trial court to resolve a timely post-sentence motion by the Commonwealth seeking modification of sentence within 120 days of its filing. As analogous support for this conclusion, Martinez reasoned at length that Pa.R.Crim.P. 720 provides a 120-day deadline for resolving post-sentence motions by the defendant. Id. at 489-90 (citing comment to Rule 720 and collecting cases).

4 There is no indication in the record the clerk of courts entered “an order on

behalf of the court, and, as provided in Rule 114, [served] a copy of the order on the attorney for the Commonwealth, the defendant’s attorney, or the defendant if unrepresented, that the post-sentence motion is deemed denied.” Pa.R.Crim.P. 720(B)(3)(c).

-4- J-S39008-25

are nullities. See generally Commonwealth v. Khalil, 806 A.2d 415 (Pa.

Super. 2002).

We have held, however, that a breakdown in the operations of the court

takes place when the court (or the clerk of court) fails to enter an order

indicating that the post-sentence motions were denied by operation of law.

See, e.g., Khalil, supra; Commonwealth v. Perry,

Related

Commonwealth v. Braykovich
664 A.2d 133 (Superior Court of Pennsylvania, 1995)
Commonwealth v. Patterson
940 A.2d 493 (Superior Court of Pennsylvania, 2007)
Commonwealth v. Khalil
806 A.2d 415 (Superior Court of Pennsylvania, 2002)
Commonwealth v. Perry
820 A.2d 734 (Superior Court of Pennsylvania, 2003)
Commonwealth v. Martinez
141 A.3d 485 (Superior Court of Pennsylvania, 2016)
Commonwealth v. West
883 A.2d 654 (Superior Court of Pennsylvania, 2005)
Commonwealth v. Valentine
928 A.2d 346 (Superior Court of Pennsylvania, 2007)
Commonwealth v. Thompson
39 A.3d 335 (Superior Court of Pennsylvania, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Com. v. Weiss, E., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-weiss-e-pasuperct-2026.