Commonwealth v. Tumolo

Dissenting Opinion by

Spaulding, J.:

I respectfully dissent.

The Commonwealth appeals from an order of the Court of Common Pleas of Philadelphia quashing eight indictments against appellee charging him with two *194counts each of conspiracy, forgery, fraudulent conversion, and false pretenses. All of the indictments were based on appellee’s insurance claims resulting from two allegedly fraudulent automobile accidents. The sole question raised by the Commonwealth is whether the trial court erred in holding that it did not have jurisdiction over the subject matter here, based on its determination that no overt act in furtherance of the alleged conspiracy was committed.

The trial judge’s opinion outlines the evidence with respect to the Commonwealth’s contention as follows: “The evidence in this case established that the Defendant is a resident of Delaware County, insured his motor vehicle through a branch office of the State Farm Insurance Company located in Delaware County. . . . [0]n December 17, 1969, a person purporting to be the Defendant called . . . the insurance company in Delaware County and reported that his automobile had been involved in an automobile accident . . . with two vehicles, one of which was owned by a person having a Philadelphia address. This accident was reported to have occurred in Delaware County. Estimates of the damage to this vehicle were made in Delaware County, and checks issued in Delaware County based upon the estimates. There was no evidence to establish that the checks were mailed to the resident in Philadelphia County.

“There was no evidence of a subsequent report to the same branch office from a person purporting to be the Defendant of an accident occurring in Philadelphia County on January 25, 1970, involving two motor vehicles, the owner of one of which had a Philadelphia address. It was testified that one of these vehicles was inspected by Quality Badiator located in Philadelphia, Pennsylvania. Again checks were issued, but there was no evidence to indicate whether these checks were picked up or mailed at a Philadelphia residence.

*195“Additionally, it was contended by tbe Commonwealth that the two accidents never occurred. There was insufficient evidence to establish that any misrepresentations were made to or by anyone in Philadelphia County, with the possible exception that there is testimony that one vehicle was inspected by a company which has an office in Philadelphia. It was never indicated that checks were issued based upon this inspection, nor that the vehicle itself was presented to the company in Philadelphia by one of the conspirators. It was clear that all of the fraudulent misrepresentations were made in Delaware County, and. that the proceeds were received outside of Philadelphia County.”

“It is . . . the law that ‘the locus of a crime is always in issue, for the court has no jurisdiction of the offense, unless it occurred within the county of trial, or unless, by some statute, it need not. . . .’: Commonwealth v. Mull, 316 Pa. 424, 426, 175 A. 418, 419 (1934).” Commonwealth ex rel. Chatary v. Nailon, 416 Pa. 280, 283, 206 A. 2d 43, 44 (1965). The crime of false pretenses is “not completed until property is obtained”, but jurisdiction exists not only in the county in which, a defendant actually obtains possession of the object in question, but also where the circumstances show that for practical purposes the object was placed in his control (e.g. — the county where the object is mailed to the defendant). Commonwealth v. Prep, 186 Pa. Superior Ct. 442, 142 A. 2d 460 (1958). Here, as noted by the trial judge, there was no evidence of the circumstances required for jurisdiction.

It is also well settled that prosecution for criminal conspiracy may be brought only in the county where the conspiracy was formed or the county where an overt act in furtherance of the unlawful combination was committed. Commonwealth v. Thomas, 410 Pa. 160, 189 A. 2d 255 (1963); Commonwealth v. Mezick, 147 Pa. Superior Ct. 410, 24 A. 2d 762 (1942). Concerning tbe *196first accident, there is clearly no evidence of any overt act having been committed in Philadelphia. The second accident (allegedly occurring January 25) docs have some ties to Philadelphia, in that one of the vehicles was allegedly inspected by a Philadelphia based firm and the accident was reported to have occurred in Philadelphia. The trial judge, however, concluded that there was no evidence that the examination was made in Philadelphia or that any checks were ever issued based upon the inspection. Further, the Commonwealth itself contends that the accident never occurred, which contention would vitiate the alleged location of the accident as an overt act on which to base jurisdiction, since if proved it would eliminate Philadelphia as the scene of any overt act by a conspirator. If, on the other hand, the accident did take place in Philadelphia, it could not have been an act in furtherance of a conspiracy to obtain money based on a fraudulent accident which never occurred. The court below was therefore correct in holding that it had no jurisdiction.1

The order of the court below should be affirmed.

Jacobs and Hoffman, JJ., join in this dissenting opinion.

Clearly there was sufficient evidence on which similar indictments could have been brought in Delaware County.