Merger of Offenses • Sentencing • “Terroristic Threats”
Commonwealth v. Martinez, PICS Case No. 17-0028 (Pa. Super. Dec. 29, 2016) Stevens, P. J. (15 pages).
Trial court properly convicted appellant of terroristic threats because an express or specific threat was not necessary to sustain a conviction and while the trial court erred in not merging the terroristic threat conviction with the robbery conviction for purposes of sentencing, the reversal did not upset the sentencing scheme of concurrent sentences. Conviction affirmed, sentence affirmed in part and reversed in part.
