Com. v. Williams, A.

CourtSuperior Court of Pennsylvania
DecidedApril 9, 2025
Docket816 EDA 2024
StatusUnpublished

This text of Com. v. Williams, A. (Com. v. Williams, 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. Williams, A., (Pa. Ct. App. 2025).

Opinion

J-A06020-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : ANDRE L. WILLIAMS : No. 816 EDA 2024

Appeal from the Order Entered February 7, 2024 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0001188-2022

BEFORE: PANELLA, P.J.E., LANE, J., and STEVENS, P.J.E. *

MEMORANDUM BY STEVENS, P.J.E.: FILED APRIL 9, 2025

The Commonwealth of Pennsylvania appeals from the order entered in

the Court of Common Pleas of Philadelphia County granting Andre L. Williams’

Motion to Dismiss, with prejudice, pursuant to the prompt trial rule under

Pa.R.Crim.P. 600. After careful consideration, we reverse and remand.

The Commonwealth charged Appellee with drug crimes and violations of

the Uniform Firearms Act on October 6, 2021. As Rule 600 mandates that

trial commence within 365 days after the filing of the criminal complaint, see

Pa.R.Crim.P. 600(A)(2)(a), the trial court appropriately set Appellee’s Rule

600 “mechanical run date” 1 as October 6, 2022.

____________________________________________

* Former Justice specially assigned to the Superior Court.

1 The Rule 600 “mechanical run date” is 365 days after the complaint is filed.

See Commonwealth v. Lear, 325 A.3d 552, 560 (Pa. 2024). J-A06020-25

On February 4, 2024, with this matter still the subject of an unresolved

pretrial motions, Appellee filed a counseled Rule 600 motion to dismiss the

charges. At the February 7, 2024, hearing on the Rule 600 motion, the trial

court observed that of the 489 days that had passed since October 6, 2022,

only 348 days were excludable time, 2 which, when added to the mechanical

run date, produced a Rule 600 “adjusted run date” 3 of September 19, 2023.

Because the trial court found that the Commonwealth had not been diligent

for the remaining 141 days, it deemed those days includable pretrial delay not

to be added to the adjusted run date. Accordingly, it concluded the

Commonwealth committed a Rule 600 violation and entered an order

dismissing all charges.

The Commonwealth appealed and raised the following issue for our

review:

2 Rule 600(C)(1) addresses excludable time as follows:

For the purposes of paragraph (A), 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 the time within which trial must commence. Any other periods of delay shall be excluded from the computation.

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

3 The adjusted run date “is the deadline for the Commonwealth to bring the

defendant to trial under Rule 600.” Commonwealth v. Walker, --- A.3d -- --, No. 2445 EDA 2023, 2025 WL 300898 (Pa. Super. filed January 27, 2025). It is calculated by adding excludable time to the mechanical run date. Id.

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Did the lower court err by dismissing all charges under Rule 600, where fewer than 365 days of includable time passed between the filing of the criminal complaint and the dismissal of the charges?

Brief for the Commonwealth as Appellant, at 6.

Our review of a trial court's order dismissing a prosecution on Rule 600

grounds is well-settled.

In evaluating Rule [600] issues, our standard of review of a trial court's decision is whether the trial court abused its discretion. Judicial discretion requires action in conformity with law, upon facts and circumstances judicially before the court, after hearing and due consideration. An abuse of discretion is not merely an error of judgment, but if 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, as shown by the evidence or the record, discretion is abused.

The proper scope of review is limited to the evidence on the record of the Rule [600] evidentiary hearing, and the findings of the [trial] court. An appellate court must view the facts in the light most favorable to the prevailing party.

Additionally, when considering the trial court's ruling, this Court is not permitted to ignore the dual purpose behind Rule [600]. Rule [600] serves two equally important functions: (1) the protection of the accused's speedy trial rights, and (2) the protection of society. In determining whether an accused's right to a speedy trial has been violated, consideration must be given to society's right to effective prosecution of criminal cases, both to restrain those guilty of crime and to deter those contemplating it. However, the administrative mandate of Rule [600] was not designed to insulate the criminally accused from good faith prosecution delayed through no fault of the Commonwealth.

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So long as there has been no misconduct on the part of the Commonwealth in an effort to evade the fundamental speedy trial rights of an accused, Rule [600] must be construed in a manner consistent with society's right to punish and deter crime. In considering [these] matters ... courts must carefully factor into the ultimate equation not only the prerogatives of the individual accused, but the collective right of the community to vigorous law enforcement as well.

Commonwealth v. Horne, 89 A.3d 277, 283–84 (Pa. Super. 2014) (emphasis added & citation omitted).

Rule 600 requires that, in a case in which a written complaint is filed, trial must commence within 365 days of the date the complaint is filed. Pa.R.Crim.P. 600(A)(2)(a). If a defendant is not brought to trial within the required time, he “may 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). The trial court must then conduct a hearing on the motion. Id. Subsection (C) further provides that when computing time for Rule 600 purposes, “periods of delay at any stage of the proceeding 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[, but a]ny other periods of delay shall be excluded from the computation.” Pa.R.Crim.P. 600(C)(1). Therefore, a Rule 600 analysis entails the following three steps:

First, Rule 600(A) provides the mechanical run date. Second, we determine whether any excludable time exists pursuant to Rule 600(C). We add the amount of excludable time, if any, to the mechanical run date to arrive at an adjusted run date.

If the trial takes place after the adjusted run date, we apply the due diligence analysis set forth in Rule 600([D]). As we have explained, Rule 600[ ] encompasses a wide variety of circumstances under which a period of delay was outside the control of the Commonwealth and not the result of the Commonwealth's lack of diligence. Any such period of delay results in an extension of the run date. Addition

-4- J-A06020-25

of any Rule 600[ ] extensions to the adjusted run date produces the final Rule 600 run date. If the Commonwealth does not bring the defendant to trial on or before the final run date, the trial court must dismiss the charges.

Commonwealth v. Carl, 276 A.3d 743, 749 (Pa. Super. 2022) (citation omitted), appeal denied, 337 MAL 2022, 292 A.3d 839 (Pa. Feb. 15, 2023).

Commonwealth v. Faison, 297 A.3d 810, 821–22 (Pa. Super. 2023), appeal

denied, 320 A.3d 82 (Pa. 2024). Determining whether the Commonwealth

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Related

Commonwealth v. SELENSKI
994 A.2d 1083 (Supreme Court of Pennsylvania, 2010)
Commonwealth v. Aaron
804 A.2d 39 (Superior Court of Pennsylvania, 2002)
Commonwealth v. Horne
89 A.3d 277 (Superior Court of Pennsylvania, 2014)
Commonwealth v. Mills
162 A.3d 323 (Supreme Court of Pennsylvania, 2017)
Com. v. Faison, W.
2023 Pa. Super. 112 (Superior Court of Pennsylvania, 2023)

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