Commonwealth v. DeSumma

OPINION OF THE COURT

FLAHERTY, Justice.

This appeal requires us to interpret Pa.R.Crim.P. 229 in reviewing the propriety of amending a criminal complaint at trial to include victims of assault who were not named in the original complaint. The trial court allowed the amendment on the ground that appellant was not surprised or prejudiced by the addition of new victims, and appellant was convicted. We reverse, due to violation of Rule 229.

The appellant, Frank DeSumma, was offended one evening by the inconsiderate driving of Frank O'Hara, who cut him off in traffic. Appellant exchanged angry words…