Commonwealth v. Crawford

In Commonwealth v. Crawford, the defendant appealed his convictions of numerous fraud-related charges in three consolidated cases. Essentially, he was found guilty of lying about his status as a military veteran to join and defraud an American Legion post. On appeal, the defendant argued that the offense of misrepresenting veteran status is unconstitutional, that the evidence was legally insufficient, and that his sentence was overly harsh and excessive. The Pennsylvania Superior Court affirmed in part, reversed in part, and remanded for resentencing. First, the Court held that the statute is neither void for vagueness nor overbroad. Next, the Court ruled that evidence was sufficient to sustain the convictions. Third, the Court found that the defendant’s arguments about the excessiveness of his sentence did not raise a substantial question and, thus, did not merit review. Lastly, the Court ruled the defendant’s sentence was illegal because he received separate sentences for his convictions of theft by unlawful taking and theft by receiving stolen property. However, the merger doctrine applied because the different crimes arose from a single criminal act, and “all of the statutory elements of one offense are included in the statutory elements of the other offense.” 42 Pa.C.S. § 9765.

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