Commonwealth v. Kurilla

BECK, Judge:

The issue is whether the four (4) year statute of limitations in the Public Welfare Code, 62 P.S. § 481(d), limits the restitution that the trial court may order a defendant to pay, to the amount which the defendant unlawfully received in the four years preceding the filing of the complaint. We do not interpret section 481(d) as imposing such a limitation. We therefore affirm the judgment of sentence.

The facts in the instant action are as follows. On May 2, 1988, the Department of Public Welfare filed a criminal complaint against appellant Robert Kurilla charging him with…