Commonwealth v. Young

In 1976, Appellant pleaded guilty to third-degree murder. He absconded to Kentucky when he was paroled. Two years later, he was convicted of rape and related offenses in Kentucky. These sex crimes carried a lifetime reporting requirement under Kentucky law.  After he served the full sentence for the crimes in Kentucky, he was transferred to Pennsylvania to serve the balance of his sentence for the murder conviction.  In early 2018, Appellant was paroled and informed he was subject to Pennsylvania’s sex offender registration requirements due to his convictions in Kentucky. He filed a pro se PCRA petition challenging his sex offender reporting obligations. The PCRA court dismissed the petition as untimely, and the Pemmsylvania Superior Court affirmed. In Commonwealth v. Young, Appellant’s appeal arose from the docket number associated with his murder conviction in Pennsylvania. However, he sought to challenge the sex offender registration requirements that arose from a judgment of sentence in Kentucky. Because those sex offender registration requirements were entirely separate from Appellant’s murder conviction or sentence, the Court lacked jurisdiction to review them on appeal. To the extent Appellant might have had a valid ex post facto claim, the Court opined that he could file a petition for review in the Commonwealth Court or “pursue another appropriate form of relief”.

STUART-YOUNG