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Commonwealth v. Snyder

Pennsylvania Superior Court

April 9, 2021

In Commonwealth v. Snyder, Appellant appealed the judgment of sentence imposed after a jury found him guilty of corruption of minors and related offenses. On appeal, he made four claims of error. The Pennsylvania Superior Court affirmed the convictions. As to the sentence, the Court affirmed in part and reversed in part. The Court ruled: 1. Appellant’s Devlin claim was not meritorious because the Commonwealth established the date of the offense with reasonable certainty; 2. The trial court did not err in failing to give a prompt complaint jury instruction; 3. Appellant waived his claims about the legality of Subchapter H of SORNA because he did not raise the claims in the trial court but first raised the claims in his 1925(b) statement; 4. The trial court erred by failing to conduct an inquiry into Appellant’s ability to pay before imposing non-mandatory fines. However, Pa.R.Crim.P. 706(C) did not require a presentence determination of  Appellant’s ability to pay before the trial court imposes costs.

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