Supreme Court of Pennsylvania

Commonwealth, Aplt. v. Lear, J.

October 24, 2024

Summary

The Supreme Court of Pennsylvania reviewed whether Pennsylvania Rule of Criminal Procedure 600 requires the Commonwealth to demonstrate due diligence before excluding pandemic‑related delays and whether such delays constitute a violation of the speedy‑trial deadline. The Court held that COVID‑19‑related court closures are “other periods of delay” excludable without a diligence inquiry and that Lear’s trial occurred within the adjusted run date, so the Rule 600 deadline was not violated. Accordingly, the Court reversed the Superior Court’s decision and vacated the remand for a diligence hearing.