J-A03031-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA

v.

BRANDI SNOWDEN 

Appellant

:

:

:

:

:

:

:

:

:

 IN THE SUPERIOR COURT OF

 PENNSYLVANIA

 No. 402 WDA 2023

Appeal from the Judgment of Sentence Entered March 8, 2023

In the Court of Common Pleas of Allegheny County Criminal Division at 

No(s): CP-02-CR-0005182-2022

BEFORE: BOWES, J., KUNSELMAN, J., and MURRAY, J.

MEMORANDUM BY MURRAY, J.: FILED: February 12, 2024

Brandi Snowden (Appellant) appeals from the judgment of sentence 

entered following her non-jury conviction of possession of a controlled 

substance.

1

 After careful review, we affirm. 

The trial court summarized the relevant facts underlying this appeal: 

On June 6, 2022[,] at about 2015 hours, Officer [Ryan] Lawrence 

observed [Appellant] at a bus stop standing up, leaning on a trash 

can, nodding off. Officer Lawrence and Officer Kerr2 approached 

[Appellant], let her know their observations and asked if she was 

okay. [Appellant] responded that she was extremely tired. Officer 

Lawrence[,] concerned for her welfare[,] requested her ID. 

[Appellant] placed her purse on the ground and searched for her 

ID. While [Appellant] searched her purse[,] the Officer saw 

syringes in plain view. [Appellant] tossed the syringes to the side 

in her purse. Officer Lawrence placed her under arrest. The 

____________________________________________

1 35 P.S. § 780-113(a)(16).

2 Officer Kerr’s first name does not appear in the certified record.
J-A03031-24

- 2 -

Officer initially testified that he then asked to search [Appellant’s] 

purse and that she agreed. On cross[-examination], the Officer 

testified that the search of her purse was incident to arrest. ... 

Upon search of [Appellant’s] purse, the Officer found the syringes, 

7 stamp bags of heroin and fentanyl marked “Popeye[,”] and a 

Ziploc bag containing methamphetamine. Upon retrieval of the 

suspected narcotics, [Appellant] was taken to the station. 

Trial Court Opinion, 7/7/23, at 2-3 (unpaginated; some capitalization 

modified; footnote added).3 

On January 25, 2023, Appellant filed a motion to suppress evidence. 

Appellant argued she was unreasonably seized by law enforcement. Motion 

to Suppress, 1/25/23, at ¶ 3(o). After an evidentiary hearing on February 2, 

2023, the trial court denied Appellant’s motion. Trial Court Order, 3/8/23. 

Following a stipulated bench trial, the trial court convicted Appellant of 

possession of a controlled substance. The trial court sentenced Appellant to 

nine months of probation on March 8, 2023. Appellant timely appealed. Both 

Appellant and the trial court have complied with Pa.R.A.P. 1925. 

Appellant presents the following issue4for our review:

____________________________________________

3 The trial court did not, as required by Pa.R.Crim.P. 581(I), “enter on the 

record a statement of findings of fact and conclusions of law as to whether the 

evidence was obtained in violation of the defendant’s rights.” However, while 

a Pa.R.A.P. “1925(a) opinion is no substitute for the failure to make findings 

of fact and conclusions of law on the record at the conclusion of a suppression 

hearing[,]” review is possible based on facts set forth in a Rule 1925(a) 

opinion. Commonwealth v. Grundza, 819 A.2d 66, 68 n.1 (Pa. Super. 

2003) (citing Commonwealth v. Reppert, 814 A.2d 1196, 1200 (Pa. Super. 

2002)). 

4

In her 1925(b) statement, Appellant also claimed law enforcement 

“unreasonably seiz[ed Appellant] without reasonable suspicion of criminal 

(Footnote Continued Next Page)
J-A03031-24

- 3 -

Did the trial court err in denying suppression because police 

arrested [Appellant] without probable cause and, thereafter, 

conducted an unlawful search incident to arrest?

Appellant’s Brief at 4. 

Preliminarily,

[a]n appellate court’s standard of review in addressing a challenge 

to the denial of a suppression motion is limited to determining 

whether the suppression court’s factual findings are supported by 

the record and whether the legal conclusions drawn from those 

facts are correct.5 Because the Commonwealth prevailed before 

the suppression court, we may consider only the evidence of the 

Commonwealth and so much of the evidence for the defense as 

remains uncontradicted when read in the context of the record as 

a whole. Where the suppression court’s factual findings are 

supported by the record, the appellate court is bound by those 

findings and may reverse only if the court's legal conclusions are 

erroneous. Where the appeal of the determination of the 

suppression court turns on allegations of legal error, the 

suppression court’s legal conclusions are not binding on an 

appellate court, whose duty it is to determine if the suppression 

court properly applied the law to the facts. Thus, the conclusions 

of law of the courts below are subject to plenary review.

Commonwealth v. Prizzia, 260 A.3d 263, 266 (Pa. Super. 2021) (citation 

omitted; footnote added). 

____________________________________________

activity.” 1925(b) Statement, 6/7/23, ¶ 10.a. This contention is not 

addressed in Appellant’s brief and is, therefore, waived. See In Interest of 

T.Q.B., 286 A.3d 270, 273 n.5 (Pa. Super. 2022) (holding that issues raised 

in a Rule 1925(b) concise statement that are not developed in the 

appellate brief are abandoned).

5 Pertinently, “[w]hen the suppression court’s specific factual findings are 

unannounced, [...] the appellate court should consider only the evidence of 

the prevailing suppression party ... and the evidence of the other party” that 

remains uncontradicted. In Int. of M.W., 194 A.3d 1094, 1097 (Pa. Super. 

2018) (quoting Commonwealth v. Millner, 888 A.2d 680, 685 (Pa. 2005)). 
J-A03031-24

- 4 -

In examining the totality of the circumstances, it is well-established that

we must give due weight ... to the specific reasonable inferences 

the police officer is entitled to draw from the facts in light of his 

experience. Also, the totality of the circumstances test does not 

limit our inquiry to an examination of only those facts that clearly 

indicate criminal conduct. Rather, even a combination of 

innocent facts, when taken together, may warrant further 

investigation by the police officer.

Commonwealth v. Cunningham, 287 A.3d 1, 11 (Pa. Super. 2022) (citation 

omitted; emphasis added). Further,

[w]e do not review the evidence piecemeal, but consider the 

totality of the circumstances in assessing whether probable cause 

existed.... If the evidence supports the findings of the trial court, 

those findings bind us and we may reverse only if the suppression 

court drew erroneous legal conclusions from the evidence.

Commonwealth v. El, 933 A.2d 657, 660 (Pa. Super. 2007) (citation 

omitted). 

Where a defendant files a motion seeking to suppress evidence, “[t]he 

Commonwealth shall have the burden of going forward with the evidence and 

of establishing that the challenged evidence was not obtained in violation of 

the defendant’s rights.” Pa.R.Crim.P. 581(H); see also id., Comment (stating 

that the standard of proof is a preponderance of the evidence). Further, “a 

defendant at a suppression hearing has the right to test the veracity of the 

facts recited in the affidavit in support of probable cause.” Commonwealth 

v. James, 69 A.3d 180, 187 (Pa. 2013) (citation omitted). When testing the 

veracity of the facts recited in the affidavit, a defendant must make “a 

substantial preliminary showing [that] the affiant knowingly and intentionally, 
J-A03031-24

- 5 -

or with reckless disregard for the truth, included a false statement in the 

affidavit.” Id. at 188 (citation omitted). 

We must address an additional preliminary matter concerning our scope 

of review. Both the Commonwealth and the trial court maintain this Court 

may not consider a police-worn body camera video that Appellant used when 

cross-examining Officer Lawrence.6 At the suppression hearing, Appellant

played a portion of the officer’s body camera video that showed he had not, 

contrary to his prior testimony, requested consent to search Appellant’s purse. 

Rather, he effectuated an arrest and thereafter conducted the search. See 

N.T., 2/2/23, at 13-14. On redirect examination, the Commonwealth relied 

on the video to bolster its argument that Appellant made no effort to explain 

the presence of syringes in her purse. Id. at 15. Although properly 

authenticated, Appellant neither marked the video as an exhibit nor moved 

for its admission into evidence. Id. at 13-15. The Commonwealth contended

during its closing argument that “the video and body cam footage is not 

evidence, it has not been admitted as evidence, so it cannot be considered by 

the Court.” Id. at 20. 

On November 21, 2023, the parties filed a “Stipulation Order to 

Supplement Certified Record on Appeal” (Stipulation). The Stipulation

____________________________________________

6 The trial court merely concluded “the [o]fficer’s body-cam video was never 

offered nor admitted into evidence.” Trial Court Opinion, 7/7/23, at 5 

(unpaginated). The Commonwealth’s argument is discussed infra. 
J-A03031-24

- 6 -

referred to and attached a section of the video the parties agreed “was played 

in open court at [Appellant’s suppression hearing].” Stipulation, 11/21/23, at

1 (unpaginated). The Stipulation confirmed the video evidence “is necessary 

for appellate review and the ultimate resolution of this case.” Id. at 2 

(unpaginated). Significantly, the Stipulation explicitly stated the 

Commonwealth did not object to the video becoming a part of the certified 

record. Id. The video evidence was thereafter transmitted to this Court as a 

supplemental record. Thus, the Commonwealth waived this issue. See 

Pa.R.A.P. 302(a) (stating an issue cannot be raised for the first time on 

appeal). 

Regardless, we conclude the video evidence is properly before us. We 

are guided by this Court’s analysis in Commonwealth v. Jones, 271 A.3d 

452 (Pa. Super. 2021).7 In Jones, we examined as a matter of first 

impression whether we could consider a surveillance video not admitted in 

evidence—but played at trial—in ruling on a defendant’s sufficiency of the 

evidence challenge. See id. at 456. The defendant stipulated at trial that the 

surveillance video was authentic, lodged no objection to the video being 

____________________________________________

7 We acknowledge the procedural posture of Jones, which involved the 

admissibility of evidence at trial, as opposed to a pre-trial hearing. This, 

however, reinforces the applicability of the holding. See Commonwealth v. 

Wroten, 257 A.3d 734, 741 (Pa. Super. 2021) (“In making the determination

that these items are part of the certified record in this appeal, we are mindful 

of the relaxed rules of evidence attendant to preliminary hearings and other 

pre-trial criminal proceedings.” (citations omitted)).
J-A03031-24

- 7 -

played, and the defendant cross-examined the witness who obtained the video 

concerning its contents. See id. at 455. On appeal, the defendant argued

“this Court [could not] consider the video recording ... because the video was 

not admitted in evidence.” Id. at 456. The parties filed a “Limited Joint 

Stipulation” stating, “the parties agree that the video was not formally 

admitted into evidence at trial and that [a]ppellant does not waive his 

contention that the video cannot be considered in ruling on the sufficiency of 

the evidence.” Id. at 456 n.2 (emphasis added). 

In concluding the video was appropriate for review, we explained

where the trial court, in fact, made a determination that the video 

was admissible before it was played, the video was in evidence 

and became part of the record once it was played without 

objection, even though no formal motion to admit it in evidence 

was made. Although it appears that there is no Pennsylvania 

precedent addressing this situation, courts in other jurisdictions 

have recognized that when a recording is played to the fact finder 

for its consideration, the recording is admitted in evidence and 

becomes part of the record even if no formal motion is made for 

its admission. Cull v. Commonwealth, 2000 WL 311169 at *3

(Va. App. Mar. 28, 2000) (holding that “[i]rrespective of any 

characterization made by the trial judge, the contents of the tape 

were admitted into evidence when the jury viewed it”); 

Kennebrew v. State, 267 Ga. 400, 480 S.E2d 1, 4 (1996) 

(defendant admitted evidence where he played tape recording 

even though he did not move the recording into evidence).

Id. at 456-57 (footnote omitted); see also Huber v. Etkin, 58 A.3d 772, 

780 n.8 (Pa. Super. 2012) (en banc) (“The decisions of courts of other states 

are persuasive, but not binding authority.”). We further observed the 

defendant “not only failed to object that the video was admitted and failed to 

object to the trial court’s consideration of it before the trial court’s verdict, he 
J-A03031-24

- 8 -

stipulated to the video’s admissibility and used it in his case and in argument 

after the Commonwealth had rested.” Id. at 457. 

Instantly, Officer Lawrence’s body camera video was played without 

objection. The Commonwealth’s statement after the parties rested “that the 

video and body cam footage is not evidence,” see N.T., 2/2/23, at 20, did not 

constitute a specific objection necessary to avoid waiver.8 Not only did the 

Commonwealth waive this argument by failing to lodge a timely objection, it 

also consented to our review of the body camera video in the Stipulation. 

Unlike the defendant in Jones, the Commonwealth stipulated to the video 

becoming a part of the certified record without any limitations. See

Stipulation, 11/21/23, at 2 (unpaginated). 

Even if the Commonwealth had neither waived its contention, nor 

consented to our review of the video by stipulation, we would conclude this 

Court may properly consider the video in evaluating Appellant’s claim. 

Although not formally admitted as evidence, both parties relied on information 

from the video to advance their arguments. Therefore, the video “was in 

evidence and became a part of the record once it was played without 

____________________________________________

8 See Commonwealth v. Pacheco, 227 A.3d 358, 374 (Pa. Super. 2020) 

(deeming a claim waived where the appellant waited until after the witness 

was excused before lodging an objection); Commonwealth v. Tucker, 143 

A.3d 955, 962 (Pa. Super. 2016) (holding appellant waived claim where he

waited until after direct and cross-examination of the subject witness, and 

after the next witness’s testimony, before raising objection). 
J-A03031-24

- 9 -

objection....” Jones, 271 A.3d at 456. Accordingly, this Court will consider 

the police-worn body camera video in our review of the merits.9 

The parties agree that Officer Lawrence was required to have probable 

cause to arrest Appellant and search her incident to arrest. 

Probable cause is made out when “the facts and circumstances 

which are within the knowledge of the officer at the time of the 

arrest, and of which he has reasonably trustworthy information, 

are sufficient to warrant a man of reasonable caution in the belief 

that the suspect has committed or is committing a crime.” 

Commonwealth v. Rodriguez, 585 A.2d 988, 990 ([Pa.] 1991). 

The question we ask is not whether the officer’s belief was “correct 

or more likely true than false.” Texas v. Brown, 460 U.S. 730, 

742 (1983). Rather, we require only a “probability, and not a 

prima facie showing, of criminal activity.” Illinois v. Gates, 462 

U.S. 213, 235 (1983) (citation omitted) (emphasis supplied). In 

determining whether probable cause exists, we apply a totality of 

the circumstances test. 

Commonwealth v. Thompson, 985 A.2d 928, 931 (Pa. 2009) (citations 

modified). “Where probable cause to arrest does not exist in the first instance, 

any evidence seized in a search incident to arrest must be suppressed.” In 

Int. of O.A., 717 A.3d 490, 495 (Pa. 1998) (citation omitted). 

Appellant argues her arrest was primarily based on Officer Lawrence’s 

observation of a syringe in her purse. She maintains the other factors the 

Commonwealth and trial court relied on in justifying her arrest did not 

establish probable cause. Appellant’s Brief at 19. In support, Appellant relies 

on Commonwealth v. Barr, 266 A.3d 25 (Pa. 2021), and Commonwealth 

____________________________________________

9 Although we may consider the video, its limited usefulness to our analysis is 

discussed further infra.
J-A03031-24

- 10 -

v. Hicks, 208 A.3d 916 (Pa. 2019), as establishing why possession of an 

otherwise lawful object, “without other indicia of illegal activity, does not 

establish probable cause of criminal activity.” Appellant’s Brief at 17. 

In Hicks, the Supreme Court considered a claim involving possession of 

a concealed firearm. The Hicks Court concluded police cannot detain an 

individual merely based on possession of a concealed firearm in public. Hicks,

208 A.3d at 936. The Court criticized per se rules that obviate the 

government’s obligation to establish reasonable, individualized suspicion: 

Unless a police officer has prior knowledge that a specific 

individual is not permitted to carry a concealed firearm, and 

absent articulable facts supporting reasonable suspicion that a 

firearm is being used or intended to be used in a criminal manner, 

there simply is no justification for the conclusion that the mere 

possession of a firearm, where it lawfully may be carried, is alone 

suggestive of criminal activity.

Id. at 937. 

Subsequently, in Barr, the Supreme Court held “that the smell of 

marijuana may be a factor, but not a stand-alone one, in determining whether 

the totality of the circumstances established probable cause to permit a police 

officer to conduct a warrantless search of a vehicle.” Barr, 266 A.3d at 28. 

The Court

[e]mphasize[d] that the realization that a particular factor 

contributing to probable cause may involve legal conduct does not 

render consideration of the factor per se impermissible, so long as 

the factor is considered along with other factors that, in 

combination, suggest that criminal activity is afoot. ... [T]he 

totality-of-the-circumstances analysis encompasses the 

consideration of factors that may arguably be innocent in 

nature. 
J-A03031-24

- 11 -

Id. at 41-42 (emphasis added). 

The Commonwealth acknowledges possession of a syringe does not 

establish probable cause as a standalone factor, but counters that Officer 

Lawrence did not rely solely on his observation of syringes

10 in Appellant’s 

purse. Instead, he relied on several factors to support Appellant’s arrest: 1)

her presence in a high crime area, 2) her “nodding off” at a bus stop, 3) her 

effort to “conceal” the syringe in her purse, and 4) her failure to explain her 

possession of the syringes. Commonwealth’s Brief at 12-14. 

Both parties cite to the analogous case of Commonwealth v. 

Bumbarger, 231 A.3d 10 (Pa. Super. 2020), as supporting their respective 

positions. In Bumbarger, the defendant was driving a vehicle with a

passenger. See id. at 13. Trooper Murarik, who had prior experience with 

the defendant, saw the defendant and confirmed he had an outstanding 

warrant for his arrest. See id. After conducting a traffic stop and taking the 

defendant into custody, the Trooper spoke with the passenger, who was also 

a known drug user. See id. at 14. The Trooper believed the passenger was

under the influence of a controlled substance and asked her to step out of the 

vehicle. See id. As she was exiting the vehicle, the Trooper observed two 

____________________________________________

10 Appellant maintains that the body camera video evidences a single syringe, 

while the Commonwealth cites to relevant portions of the suppression hearing 

transcript establishing that the officer observed multiple syringes. Regardless, 

the number of syringes viewed by Officer Lawrence is irrelevant to our 

analysis. 
J-A03031-24

- 12 -

syringes under the passenger seat. See id. The Trooper conducted a 

probable cause search of the vehicle11 and recovered a firearm and 

methamphetamine. See id. at 14. 

On appeal, the defendant challenged the trial court’s denial of his 

suppression motion, following his convictions for drug and firearm offenses. 

See id. at 15. Relevantly, he claimed that law enforcement searched his 

vehicle without probable cause. See id. The defendant argued “the two 

syringes the Trooper claimed he observed when he had the passenger step 

out of the vehicle did not possess an incriminating character that was 

immediately apparent....” Id. at 15. In concluding his claim lacked merit, this 

Court relied on the following relevant facts:

Here, Trooper Murarik approached the passenger of the vehicle as 

part of the lawful stop. Trooper Murarik knew [passenger], and 

knew of her drug use and sales history. [Passenger’s] appearance 

reflected that she was under the influence of drugs. Moreover, 

when Trooper Murarik lawfully asked [passenger] to exit the 

vehicle in accordance with the lawful stop, he observed drug 

paraphernalia in plain view. Accordingly, we conclude that 

Trooper Murarik did not unlawfully detain [passenger] or ask her 

to exit the vehicle. Furthermore, given his observation of 

[passenger’s] appearance, his knowledge of [passenger’s] druguse history, and the observation of the syringes, Trooper Murarik 

had reason to suspect criminal activity. Thus, Trooper Murarik 

had probable cause to search the vehicle. 

____________________________________________

11 The Bumbarger case was decided prior to our Supreme Court’s 

pronouncement in Commonwealth v. Alexander, 243 A.3d 177, 195 (Pa. 

2020), that “warrantless vehicle searches required both probable cause and 

exigent circumstances.”
J-A03031-24

- 13 -

Id. at 18 (citations and footnote omitted). We further recognized “hypodermic 

syringes are specifically included in the definition of ‘drug paraphernalia[,]’”

and “the circumstantial evidence in this case regarding the syringes supports 

the conclusion that they were drug paraphernalia.” Id. at 19 (citation 

omitted). 

Furthermore, the location and unsecured nature of the syringes 

on the floor of the vehicle were not consistent with use of the 

syringes for medical purposes. Moreover, [passenger] appeared 

to be under the influence of drugs, and the syringes were in close 

proximity to her person in the vehicle. Upon having her attention 

directed to the syringes, [passenger] did not indicate that the 

syringes were for medical use. Also, [passenger] was known by 

Trooper Murarik to use and sell drugs. Given the totality of 

circumstances, it was reasonable for Trooper Murarik to believe 

that these syringes were being used for a criminal purpose. Thus, 

discovery of these syringes in connection with the other 

relevant factors suggesting illegal drug use constituted 

probable cause to search the vehicle.

Id. (citations omitted; emphasis added). 

Instantly, we conclude Appellant’s arrest, under the totality of the 

circumstances, was supported by probable cause. See Barr, 266 A.3d at 41-

42. On direct examination, Officer Lawrence testified that he observed 

Appellant “nodding off” at a bus stop. N.T., 2/2/23, at 5. He elaborated on 

cross-examination that, prior to police engaging her, Appellant was leaning on 

a trash can for support. Id. at 11. Officer Lawrence testified that the area in 

which he interacted with Appellant was a “high drug area.” N.T., 2/2/23, at 

7. He further testified that syringes like those found in Appellant’s purse are 

commonly used for the injection of illegal drugs, and that he believed 
J-A03031-24

- 14 -

Appellant attempted to move the syringes out of sight to conceal them. Id.

at 7, 12. 

Under the totality of the circumstances, Officer Lawrence’s observations

support the trial court’s conclusion that Appellant’s arrest was lawful. See 

also Commonwealth v. Laird, 988 A.2d 618, 627 (Pa. 2010) (indicating that 

flight and concealment can constitute circumstantial proof of consciousness of 

guilt); Commonwealth v. Jordan, 212 A.3d 91, 97 (Pa. Super. 2019) 

(same). 

We are not persuaded by Appellant’s contention that the body-worn 

camera video supports her assertion that Officer Lawrence arrested her 

without probable cause. She maintains the video: 1) does not show her 

“nodding off”; 2) “only showed one syringe”; 3) showed that it was daylight12

at the time of the interaction; and 4) showed that the interaction occurred “in 

the area’s business district.” Appellant’s Brief at 19-21. While Appellant 

draws conclusions from the body camera video, she did not question Officer 

Lawrence regarding any of the above observations. Appellant effectively asks 

this Court to supplant the trial court’s judgment regarding the record with our

____________________________________________

12 We note that neither party elicited testimony concerning the time of day at 

the suppression hearing. Despite the trial court’s assertion that the police 

interaction occurred “at about 2015 hours,” Trial Court Opinion, 7/7/23, at 2 

(unpaginated), we do not consider this in our analysis. See Commonwealth 

v. Yandamuri, 159 A.3d 503, 516 (Pa. 2017) (“Our scope of review of 

suppression rulings includes only the suppression hearing record and excludes 

evidence elicited at trial.”) (citations omitted)). 
J-A03031-24

- 15 -

own. The trial court watched the video at the suppression hearing and listened 

to the testimony of Officer Lawrence. “It is within the suppression court’s sole 

province as factfinder to pass on the credibility of witnesses and the weight to 

be given their testimony.” Commonwealth v. Luczki, 212 A.3d 530, 542 

(Pa. Super. 2019). Appellant failed to develop any testimony that would cause 

this Court to conclude the trial court abused its discretion when it formulated 

legal conclusions based on the record before it. 

Finally, in addition to arguing that the body camera video shows the 

police interaction did not occur in a “high crime area,” Appellant claims that 

Barr, above, “found a neighborhood’s ‘characteristics’ to be irrelevant to a 

probable cause analysis.” Appellant’s Brief at 22. This claim mischaracterizes 

the Barr holding, wherein the arresting officer “stated on at least two 

occasions that he conducted a probable cause search of the vehicle in question 

based upon the smell of marijuana.” Barr, 266 A.3d at 44. In Barr, the 

defendant’s presence in a high crime area was irrelevant because “troopers 

simply stopped a vehicle for a minor traffic violation and then smelled 

marijuana.” Id. at 44; see also Commonwealth v. Joseph, 34 A.3d 855, 

863-34 (Pa. Super. 2011) (“[A] police officer’s observance of a defendant’s 

conduct [in] a ‘high crime area’ may, along with other factors, contribute to a 

finding of probable cause.”) (citation omitted)). 

For the foregoing reasons, Appellant’s issue merits no relief.

Judgment of sentence affirmed.
J-A03031-24

- 16 -

Judge Bowes joins the memorandum.

Judge Kunselman files a dissenting memorandum.

DATE: 02/12/2024