Commonwealth v. Lewis

WIEAND, Judge:

The issue presented by this Commonwealth appeal is whether the entry of a guilty plea can be equated with commencement of trial for Rule 1100 purposes. We hold that the tendering of a guilty plea by an accused signifies the commencement of trial regardless of whether that plea is accepted immediately by the trial court or is taken under advisement. In so holding, we expressly overrule the earlier ruling of a panel of this Court in Commonwealth v. Cox, 276 Pa.Superior Ct. 29, 419 A.2d 78 (1980) (Watkins, J., dissenting).

The facts pertinent to the instant case are as follows. On…