Commonwealth v. Forman

JOHNSON, Judge.

We are asked to consider whether the corpus delicti rule, which prohibits criminal convictions based solely upon a confession of the accused, applies to proceedings involving summary offenses. We hold the rule applicable and accordingly reverse judgment of sentence and direct that the defendant be discharged.

At the conclusion of a trial de novo in the Court of Common Pleas of Bradford County, Kenneth B. Forman was found guilty of the summary offense of Unlawful Use of Lights While Hunting, 34 Pa.C.S. § 2310(a)(2). He was immediately sentenced to pay a fine of $600.00 and costs.…