Background
J-A05044-26 NON-PRECEDENTIAL DECISION – SEE SUPERIOR COURT O.P. 65.37 COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : SHANACE R. ARMSTRONG WOODS : : Appellant : No. 164 EDA 2025 Appeal from the Judgment of Sentence Entered December 13, 2024 In the Court of Common Pleas of Monroe County Criminal Division at No(s): CP-45-CR-0000396-2018 BEFORE: KUNSELMAN, J., NICHOLS, J., and SULLIVAN, J. MEMORANDUM BY SULLIVAN, J.: FILED JULY 22, 2026 Shanace R. Armstrong Woods (“Woods”) appeals from the judgment of sentence imposed after the trial court found her in violation of probation (“VOP”). Woods contends the trial court imposed an illegal VOP sentence because her original probationary sentence expired before her violation. Because the trial court was entitled to rely on a Pennsylvania Department of Corrections (“DOC”)/Board of Parole (“Board”)1 adjustment to a sentence when determining the maximum date of her original probationary sentence, Woods has not demonstrated her VOP sentence is illegal, and we affirm. The facts and procedural history of this appeal are as follows. In 2018, Woods pleaded guilty to possession with the intent to deliver heroin (“PWID”) and possession of an instrument of crime (“PIC”). In February 2019, the trial ____________________________________________ 1 Although there are some references in the record to the Board of Probation and Parole, subsequent legislation effected a name change to the Board of Parole.
ion of the letter containing the 2021 adjustment into the record, Woods has included in her reproduced record a copy of that letter, which corroborates the officer’s testimony about the contents of the 2021 adjustment. Neither Woods nor the Commonwealth discuss in depth the 2021 adjustment’s reference to a “DOC sentence restructure,” upon which the Board apparently (Footnote Continued Next Page) -2- J-A05044-26 the Commonwealth determined Woods’s probation sentence for PIC started in March 2024 and would end in March 2025. See Petition for Violation of Special Probation, 6/25/24, unpaginated at 2; N.T., 9/6/24, at 7.4 In June 2024, police arrested Woods for new drug offenses, and the Commonwealth filed a petition to revoke Woods’s original probationary sentence. Woods objected to the revocation proceeding and challenged the Commonwealth’s assertion she was still serving the original probation sentence for PIC when she committed the new drug offenses. Woods acknowledged the 2021 adjustment to her original PWID sentence but claimed the Board lacked the authority to modify her sentence without a court order or a violation of parole. See id. at 3; see also N.T., 7/31/24, at 6. The Commonwealth conceded that, absent the 2021 ____________________________________________ modified a prior action and adjusted the maximum date. Moreover, to the extent the Board action in March 2020 referred to Woods’s release, her release would have occurred after the governor’s declaration of a state of emergency due to the pandemic but before the governor ordered the DOC to establish a reprieve of sentence of incarceration program in April 2020.
The Court’s Holding
conclusions that the revocation proceeding, and imposition of a VOP sentence, were lawful, and we conclude Woods’s challenge to the legality of VOP sentence merits no relief. Date: 7/22/2026 ____________________________________________ 7 It bears noting that Woods presented no evidence that she was assured the time she spent on release during the pandemic would be credited to her PWID sentence or that she was subject to any restriction during that release. Super. 2012) (discussing credit for time spent while erroneously at liberty). – 10 –
The decision applies Pennsylvania law to the issues preserved in this appeal and explains the governing standard in the court’s own terms. The disposition controls the parties’ next steps and supplies guidance for litigants confronting the same procedural or substantive question.
Key Takeaways
- conclusions that the revocation proceeding, and imposition of a VOP sentence, were lawful, and we conclude Woods’s challenge to the legality of VOP sentence merits no relief.
- Date: 7/22/2026 ____________________________________________ 7 It bears noting that Woods presented no evidence that she was assured the time she spent on release during the pandemic would be credited to her PWID sentence or that she was subject to any restriction during that release.
- Super. 2012) (discussing credit for time spent while erroneously at liberty). – 10 –
Why It Matters
Superior Court allows reliance on an unchallenged state-sentence recalculation Pennsylvania practitioners should read the ruling with particular attention to the court’s treatment of preservation, the applicable standard, and the remedy. Those points will shape how comparable claims are framed in trial courts and reviewed on appeal.