Commonwealth v. Bradley

The Superior Court affirmed the aggregate sentence — 17 to 34 years of incarceration for non-violent offenses — but remanded for the trial court to impose a RRRI minimum term. The Court held that, when a defendant is being sentenced for a non-violent crime, their single prior conviction for a non-enumerated crime of violence does not alone constitute a “history of past violent behavior” so as to trigger ineligibility for RRRI. 

BRADLEY