July 24, 2026 – Today, the Pennsylvania General Assembly ran out of time to establish a legislative solution to the ruling in Commonwealth v. Lee, the landmark Pennsylvania Supreme Court case that declared the state’s felony murder sentencing scheme unconstitutional. Now that the 120 days the Court gave the General Assembly to create new sentencing guidelines have passed, Public Defender offices must prepare to litigate whether Lee applies retroactively to hundreds of cases across the Commonwealth. To prepare them to take on this work, PDAP has launched the Lee Resentencing Toolkit, now available through the password-protected Defender training library.
Meaningful resentencing hearings require meaningful representation. This means investigating decades-old cases, uncovering mitigating evidence, documenting rehabilitation, and presenting each client’s individual culpability to the court. The Lee toolkit is full of sample documents, guides, templates, and external resources to prepare Public Defender’s offices to handle these cases on both an individual and organizational scale.
PDAP thanks Annie Ruhnke (Director of Mitigation, YSRP) for her help with the mitigation materials on this page, and Alexis Climes (Manager of Investigations, Allegheny County) for her help with the investigative materials. We also thank the Abolitionist Law Center (ALC), whose multi-year campaign on felony murder, including litigating Derek Lee’s case, made hope possible for every person serving life without parole for felony murder.
Our mission is to provide tools, strategies, mutual support, training and information to Public Defender Offices in Pennsylvania; to be the voice of public defense in Pennsylvania; and to promote best practices in the leadership, management, and administration of justice in Pennsylvania.
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