Commonwealth v. Stevenson, R., Aplt.

Summary

The Supreme Court of Pennsylvania held that a defendant does not waive or forfeit appellate review of a prior-conviction admissibility ruling by preemptively introducing the conviction after the trial court definitively denies a motion in limine to exclude it. The court concluded that Pennsylvania Rule of Evidence 103 permits appellate review without renewing the objection and that the contrary federal approach conflicts with Pennsylvania law and fairness principles. The court reversed the Superior Court's judgment and remanded for consideration of the merits of the evidentiary challenge.