In Re Private Complaint of Adams

BECK, J.:

¶ 1 In this appeal we decide inter alia what evidence a trial court may consider when it reviews a district attorney’s denial of a private criminal complaint. We hold that the trial court may review all evidence that the district attorney considered in making her decision and is not limited to reviewing the four corners of the private criminal complaint. We affirm.

¶ 2 While he was on the street protesting President Clinton’s appearance in Philadelphia, appellant Donald Adams was involved in a physical confrontation with members of the Teamsters Union. Television crews captured the…