Commonwealth v. Black

Weeks after sentencing, the clerk’s office assessed certain court costs and prepared a bill of costs but did not provide it to the defendant. Some of these costs were imposed without statutory authority to impose them. Because the time to file a post-sentencing motion had already passed, the defendant’s counsel - who learned of these costs by happenstance - filed an appeal within the timeframe to do so. The Superior Court refused to consider the appeal, reasoning that the defendant should have first somehow raised this issue with the trial court, even though the costs were not assessed until weeks after sentencing and in violation of due process by failing to notify the defendant.