Commonwealth v. Stryker

The defendant, Dawn E. Stryker, appeals from an order denying her motion to terminate probation claiming that she faces additional punishment due to poverty. Because further findings are needed, we must remand the matter.

Background. In June of 2008, the defendant admitted to sufficient facts on charges of larceny over $250 and identity fraud stemming from her embezzlement of over $35,000 from her employer. She was sentenced to two years of probation with, as relevant here, a condition that she pay $28,200 in restitution. The restitution was to be paid in installments of "not less than $100…