Commonwealth v. Skipper
Superior Court of Pennsylvania
294 A.2d 780 (1972)
Relevant factsFree
Skipper (defendant), a prison inmate, arranged for another inmate to smuggle hacksaw blades into the prison in exchange for payment; prison officials intercepted a note referencing the blades and found two of them in Skipper's cell before any escape attempt occurred. Skipper was convicted of attempted prison escape and appealed pro se.
IssueFree
Whether, in Pennsylvania, the criminal offense of attempt requires the defendant to perform an overt act that is sufficiently proximate in time to the intended crime.