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SUBSTANTIAL DEVIATION FROM WORK RELEASE PROGRAM CONSTITUTES ESCAPE

We conclude that [Appellant’s actions] constituted a substantial deviation from his work-release program to establish the offense of escape where, although Appellant maintained contact with his work and the prison, he never went to work. Moreover, Appellant also stipulated that after he left the prison, he went to his girlfriend’s house for one hour, and left that location where his whereabouts were unknown for approximately three hours. Com v. Waugaman, No. 170 MDA 2017 (July 13, 2017).

CASE LINK:  http://www.pacourts.us/assets/opinions/Superior/out/J-S42004-17o%20-%2010317062321238378.pdf?cb=1

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