Prison Sentence Upheld for Man Who Posted Custody Hearing Video to Facebook
A man criminally charged for recording a child custody hearing and posting it on Facebook cannot escape his 11-and-a-half-to-23-month prison sentence.
January 02, 2018 at 07:45 PM
3 minute read
A man criminally charged for recording a child custody hearing and posting it on Facebook cannot escape his 11-and-a-half-to-23-month prison sentence.
The three-judge Pennsylvania Superior Court panel consisting of Judge John T. Bender and Senior Judges John L. Musmanno and Correale F. Stevens upheld the sentence against Patrick Cline in a Dec. 29 order. Cline was convicted of violating the state Wiretapping and Electronic Surveillance Control Act.
Cline challenged the sufficiency of the evidence that he knew recording and posting the video online was illegal, citing his testimony that he didn't know he wasn't allowed to record the closed-door hearing. Cline argued that the “no cellphone” signs in the courtroom said nothing about filming and that he did not consider the proceedings to be confidential.
“Critically in this regard, appellant fails to advance any argument that the custody conference did not involve protected 'oral communications' for purposes of the Wiretap Act,” Stevens wrote in the court's opinion. “Instead, he argues only that it was the commonwealth's burden to prove he knew the Wiretap Act proscribed the conduct in which he engaged, and absent such proof, his misunderstanding of the Wiretap Act's scope could serve as a viable defense.”
However, Stevens said it could not.
“The prosecution of the Wiretap Act charge against appellant turned, instead, on proof that appellant knowingly or intentionally intercepted and disclosed discussions that qualified as 'oral communications' under the statute,” Stevens said in a published opinion. “That is, the commonwealth was required to prove appellant knowingly or intentionally committed the acts proscribed under the statute; it was not required to prove appellant knew the law proscribed such acts, as a defendant's knowledge of the law is not an element of the offense. For this reason, we reject appellant's sufficiency challenge as articulated.”
Cline also contended that the prosecution violated his due process rights, but Stevens said Cline failed to raise that issue with the trial court first.
“The law is clear that 'issues, even those of constitutional dimension, are waived if not raised in the trial court. A new and different theory of relief may not be successfully advanced for the first time on appeal,'” Stevens said citing the 2009 Superior Court ruling in Commonwealth v. Santiago.
Cline is represented by Allentown attorney Robert Long, who could not be reached for comment. The case was prosecuted by the Lehigh County District Attorney's Office.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllPa. High Court to Weigh Parent Company's Liability for Dissolved Subsidiary's Conduct
3 minute readDon’t Settle for the Minimum: Finding Constitutional Claims Closer to Home
7 minute readMatt's Corner: RPC 8.4(d)—Conduct Prejudicial to the Administration of Justice
2 minute readTrending Stories
- 1Judicial Ethics Opinion 24-68
- 2Friday Newspaper
- 3Judge Denies Sean Combs Third Bail Bid, Citing Community Safety
- 4Republican FTC Commissioner: 'The Time for Rulemaking by the Biden-Harris FTC Is Over'
- 5NY Appellate Panel Cites Student's Disciplinary History While Sending Negligence Claim Against School District to Trial
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250