Com V Grigger D

Devon Grigger appealed the revocation of his probation following a 2016 guilty plea to multiple offenses including aggravated assault and vehicle-related charges, which resulted in an aggregate sentence of 11½ to 23 months' imprisonment followed by five years' probation. In 2022, while on probation, he was arrested in Montgomery County for drug offenses and firearm violations, leading to a 2023 conviction and 6–12 year sentence. The Philadelphia County court revoked his probation in 2024 for these violations, imposing an additional 1½ to 3 years' imprisonment. Grigger argued the sentence was excessive and the court failed to adequately consider his rehabilitative needs or order a presentence investigation (PSI). The appellate court affirmed the judgment, finding the trial court had sufficient information from Gagnon summaries and defense input to make an individualized sentencing decision, though it noted displeasure with the lack of a PSI.

Did the lower court err as a matter of law, abuse its discretion, and violate general sentencing principles, when it imposed a manifestly excessive sentence which failed to address [Appellant's] clear drug problem and rehabilitative needs?

The court affirmed Appellant's judgment of sentence after determining that the trial court made a fully informed, individualized sentencing decision without ordering a presentence investigation (PSI). The trial court reviewed Appellant's probation history, including drug test results and Gagnon summaries, and defense counsel provided information on Appellant's background and rehabilitative efforts. The court concluded the sentence was appropriate under the Sentencing Code and did not violate general sentencing principles.

The revocation court granted Appellant nunc pro tunc relief to file a post-sentence motion nunc pro tunc seeking reconsideration of his sentence but denied his motion for reconsideration. Appellant's timely appeal followed.

The court applied Pennsylvania Rule of Criminal Procedure 702 and 42 Pa.C.S.A. § 9721(b), emphasizing that a sentencing court must have sufficient information to make an individualized decision. While the trial court did not order a PSI report, it relied on prior probation records and defense counsel's input to satisfy the requirement for an informed sentencing decision, thus avoiding a manifest abuse of discretion.