Commonwealth v. Bryant

Summary

The Pennsylvania Superior Court affirmed Khalil Bryant's aggregate sentence following convictions for burglary, stalking, and contempt of protection from abuse orders. The court held that intent to violate a PFA order may satisfy the intent-to-commit-a-crime element of burglary, relying on Commonwealth v. Majeed. The court also concluded that the evidence supported a criminal intent to harass or stalk based on Bryant's repeated unauthorized entries and communications.

Holdings

1. A defendant's intent to violate an active PFA order may satisfy the intent-to-commit-a-crime element of burglary.
2. The Commonwealth need not allege or prove the particular crime the defendant intended to commit after entering a private residence by criminal means; criminal intent may be inferred from the totality of the circumstances.

Questions Presented

1. Whether the evidence was sufficient to establish the intent-to-commit-a-crime element of burglary where the intended criminal conduct was Bryant's violation of a PFA order.

Disposition

affirmed