The Pennsylvania Supreme Court has yet again addressed the issue of proving a prima facie case at a preliminary hearing. The Supreme Court has clarified that inadmissible hearsay alone will not be adequate to identify a defendant at a preliminary hearing.

The high court initially sought to clarify when the commonwealth may properly use hearsay evidence to establish a prima facie case at a preliminary hearing in Commonwealth v. Ricker, 135 A.3d 175 (Pa. 2016), an appeal dismissed as improvidently grant, and in Commonwealth v. McClelland, 233 A.3d 717 (Pa. 2022).