PA: For resisting arrest on a warrant, the state has to prove the warrant valid

“To prove the lawful arrest element of resisting arrest where the resisted arrest is premised on an arrest or bench warrant, the Commonwealth must produce evidence of the validity of a warrant beyond its mere existence. Because the Commonwealth failed to produce any evidence of the warrants’ validity in this case, the evidence was insufficient to sustain Steadly’s conviction for resisting arrest.” Just being in a database doesn’t mean an arrest warrant is valid. It could have been recalled or already served but not cleared out. Commonwealth v. Steadly, 2026 Pa. LEXIS 1268 (July 21, 2026).

“First, although Defendant broadly claims that the representations in the paragraphs contained in the ‘Prior Applications’ section of the affidavits were false or misleading, he does not pinpoint any particular statement in those paragraphs which is supposedly false or misleading. Instead, Defendant alleges that those paragraphs were designed to portray a large-scale drug trafficking network led by him, which did not exist. Defendant’s vague, unsupported assertion is insufficient to warrant relief under Franks.” United States v. Maragh, 2026 U.S. Dist. LEXIS 161604 (W.D. Pa. July 21, 2026).*