Sunday, September 9, 2012

Penn State Marijuana Possession 101 - Where Not to Smoke on Campus

Dorm Room
            I have been a criminal defense lawyer in State College since 2004, and I have handled hundreds of marijuana possession cases that are filed by the police against Penn State students.  Incoming freshman tend to be cited after getting caught in three areas.  First, many freshman smoke
marijuana in their dorm rooms, and they believe that keeping the window open and smoking next to a fan that blows the smoke out the window will be sufficient to keep the odor from remaining in their room.  Others exhale the marijuana smoke through papertowel rolls stuffed with dryer sheets in an attempt to mask the smell, and many try to wedge a towel at the base of the door to prevent the marijuana odor from emanating into the hallway.  Obviously, if the person is calling me, the steps taken to avoid detection were not successful. 

Law Building & Arboretum
            In the recent past, many freshmen would be charged with marijuana possession case after they were cited in the Rose Gardens on campus.  In one of my prior cases, the Penn State Police approached a client and three others as they stood under a tree in the Rose Garden, and the police officer ordered them to step into the open.  My client ran, which caused the police to give chase and call for backup office, and my client was ultimately tackled, arrested, searched, and charged with marijuana possession.  The officers had not smelled marijuana as they approached, but they suspected that marijuana was being smoked based upon the location.  I filed a motion and argued that the police did not have probable cause to arrest my client, so all evidence should be suppressed.  I believe that the district attorney knew that I should probably win, so the district attorney issued a plea offer that required my client to plead guilty to two summary charges in exchange for the dismissal of the misdemeanor drug possession and paraphernalia charges. 

I believe that the Rose Gardens were replaced with the construction of the Dickinson Law School Building and the Arboretum.  While the Rose Gardens may have disappeared, the area still draws many marijuana smokers, and the smokers are routinely cited at the law building and the Arboretum.  Since the police are familiar with the apparent draw of marijuana smokers to this area, the Penn State Police routinely patrol these areas for marijuana related activity.

Parking Decks
            The Penn State Police also patrol the parking decks near East Halls looking for marijuana smokers that incorrectly assumed that the parking deck would be a good out-of-the-way spot.  Not only do the police patrol the parking decks, they also use the elevantion from the upper decks to serve as surveillance stations.  From the upper levels of the parking decks, the police have an 
unobstructed view of entrances to some of the dorms.  The police know that people smoking cigarettes will smoke right outside the dorm entrance, whereas people smoking marijuana cigarettes will walk around the side of the dorm and smoke near some trees or other out-of-the-way location.  If an officer sees someone walk away from the entrance and light something, the officer conducting surveillance will then either leave the garage to investigate or radio another Penn State Police officer to investigate.  In many cases, the officers approach, smell the odor of marijuana, and then detain the person to conduct a marijuana possession investigation.  Courts have held that the odor of marijuana can be sufficient to establish probable cause.

What Should I Do If I Am Charged With Marijuana Possession
            While marijuana possession is legal in some states, it is NOT legal in Pennsylvania.  In Pennsylvania, a charge of possessing less than 30 grams of marijuana is a misdemeanor offense that is punishable by up to 30 days in jail, $500.00 fine, and at least a 6 month suspension of Pennsylvania driving privileges. 

If you are charged with marijuana possession, you should contact a criminal defense attorney that has experience in handling drug cases in the county in which the charge was filed.  While the laws in Pennsylvania are the same in every county, the way that cases are handled differs from county to county as you have different court systems and different district attorneys making decisions.  For example, in areas such as Pittsburgh of Philadelphia, misdemeanor marijuana possession charges may be resolved by a guilty plea to a summary charge of disorderly conduct.  However, in more rural areas that have less crime, such as State College and Lock Haven, the prosecutors rarely resolve misdemeanor drug charges via a plea to a summary offense.  Most State College criminal defense attorneys offer free consultations, so you can have multiple attorneys review your case and give you feedback at no cost.  You should investigate the attorney on the web and review websites such as Avvo for the lawyer’s overall ratings as well as positive reviews written by former clients.  The attorney should be able to explain your options to you and should also be able to discuss cases in which the attorneys has employed strategies to obtain favorable results for clients.  The police and court system treat the marijuana possession charges very seriously, and so should you.

Jason S. Dunkle has been a State College criminal defense lawyer since 2004.  His law office, JD Law, P.C., is located in downtown State College, within walking distance of the University Park Campus of Penn State University.  If you or someone you know has been charged with a DUI or other criminal offense, contact JD Law at (814) 954-1094 and schedule a FREE CONSULTATION.

Saturday, September 8, 2012

Is a Daycare Facility a "School" to Trigger "Drug Free School" Mandatory Minimum Sentence

“Drug Free School Zone” 
Mandatory Minimum Sentence
          In Pennsylvania, if a person is convicted of a violating section 780-113(a)(30) of the Drug Act, which generally prohibits the delivery, possession with intent to deliver, or the manufacture of drugs, and if the delivery of drugs occurs within 1,000 feet of the real property of any “school”, then the person is subject a two year mandatory minimum sentence.  This mandatory 
minimum sentence is commonly referred to as the “drug free school zone” law.  Many people believe that the “drug free school zone” law is intended to prevent drug dealing to children, but there is actually another mandatory minimum sentence law that punishes drug deliveries to people under 18.  The intent behind the “drug free school zone” is that drug dealing is often associated with guns and violence, and the legislature is seeking to punish people more severely that bring the dangerous activity in the vicinity of schools.  While the law was passed with good intentions, the Pennsylvania Sentencing Commission, based at Penn State University, actually recommended to the legislature that the law should be repealed.

Is a Daycare Facility a “School”
          A recent case required the Superior Court of Pennsylvania to determine whether a daycare facility should be considered a preschool and thus trigger the “drug free school zone” mandatory minimum sentence.  In the case, the prosecution argued that since the daycare facility was licensed by the Department of Health and engaged in some educational activities on a daily basis, it was in fact a preschool.  The Court held that it was a daycare facility and not a preschool because the facility did not employ any state licensed teachers and did not consider itself to be a preschool.  The facility called itself a daycare.

While the Court held that the daycare was not a preschool, it still had to consider whether a daycare facility should be considered a “school” for purposes of the “drug free school zone” statute.  The prosecution argued that since the laws intent is to protect children from the danger of drug activity, the legislature intended the phrase “school” to include a daycare facility.  As the “drug free school zone” statute is a criminal law, the Court noted that it is required to strictly construe the words in the law and cannot give them extra meanings or definitions.  The Court stated that other Pennsylvania law referenced both schools and daycare facilities.  If the legislature had intended to include daycare facilities under the school zone mandatory minimum sentencing scheme, then it needed to include such language in the law.  As the “drug free school zone” only references “school” and not a daycare facility, the court stated that a daycare facility would not trigger application of the “drug free school zone” law.

Impact on State College Drug Delivery Cases
          This case will probably have a minimal impact on how drug cases are handled in Centre County.  The “drug free school zone” mandatory minimum sentence law will continue to have a huge impact on downtown State College drug delivery cases.  The word “school” includes both private and public 
elementary, high school, colleges, and universities.  Much of downtown State College falls within a “drug free school zone” based upon the presence of Penn State University, the State College School District, and the downtown State College area has a plethora of churches that have preschool programs.  This case may cause drug defense attorneys to more closely scrutinize a preschool facility and try to argue that the facility is in fact a daycare and not a “school.”  Regretfully, if the defense attorney’s argument is rejected the judge, the client is the ultimate loser as the client is sentenced to a mandatory minimum sentence of two years incarceration, often for giving a small amount of marijuana to a friend.

Monday, September 3, 2012

How to Get Caught Underage Drinking at a Penn State Football Game

 I wrote this article a few years ago, but it is just as applicable today, and I felt that I should give it a few updates and re-post with Penn State's first home football game being this weekend.  The football tailgate and pre-gaming will involve plenty of alcohol being consumed, and much of that consumption will be by minors.  That means that Penn State students and other football fans will be facing Underage Drinking summary citations and misdemeanor Furnishing Alcohol to Minors charges.  I have been defense lawyer in State College since 2004, so I have represented thousands of Penn State students charged with criminal offenses and thereby know why many people get in trouble at tailgates at Beaver Stadium.  Below is a list of typical ways in which Penn State students and visitors have been caught over the years.
Public Urination– many Penn State tailgaters tire of the long lines at the porta-potties and go looking for trees, cars…..My personal favorite was someone that urinated next to a police car in which a uniformed officer was sitting
Push Over a Porta-Potty – either people were angry at waiting in line or simply thought that it was a good idea
Use “beer muscles” – pick a fight with a friend, another spectator, or the ticket attendant at the game that recommends that you head home before the police are summoned because you are too drunk to enter the stadium
Throw something at the Game –instead of watching the game, annoy other spectators by throwing things as them so they contact the police or security
Look and Act Guilty – When you see the uniformed officer walk by, immediately put down your beer and begin to walk away so that all the undercover officers know that you are underage and trying to avoid getting caught 

Penalties for Underage Drinking
      While Underage Drinking is only a summary offense, it actually carries substantial penalties, including a maximum fine of $500.00 and 90 day suspension of driving privileges for a first offense.  The fine for second offense convictions of Underage Drinking increase to $1,000.00.  The penalties increase for subsequent offenses, and the greatest penalties tend to be the license suspensions.  For a second offense, the suspension is 1 year, and third or subsequent offenses the suspension is 2 years.  It is also critical to note that only first-time Underage Drinking offenders are eligible to receive a “bread and butter” or Occupational Limited License.  Many Penn State graduates that receive multiple Underage citations during their years at Penn State graduate and enter the job market without the ability to drive.
Only a Fool Has Himself as Lawyer & Ignorance is NOT Bliss

            Generally speaking, you should not represent yourself.  Too many people claim that they cannot afford an attorney, so they contact the officer on their own, or go to court and admit everything to the judge with the hope of leniency.  Anything that you tell the officer or the judge can and will be used against you.  Also, many people mistakenly believe that the police must use 
breathalyzers in Underage Drinking cases.  To the contrary, breath tests are generally not admissible in Underage case IF the defense raises the appropriate objection at the right time.  If the defense does not object to evidence, such as the breath test or hearsay testimony, then the evidence is admitted into evidence and considered by the judge.  Another strategy to use in Underage cases is to seek suppression of evidence.  Again, the burden is on the defense to raise proper arguments to seek suppression, and, if the arguments are not made, the court can consider the evidence.  I have obtained favorable results for many clients charged with Underage Drinking.  

For more info about Underage Drinking, check out this FAQ page on my website.  If you have been charged with a criminal offense in State College, Lock Haven, or Altoona, contact my office for a FREE consultation. 

Jason S. Dunkle has been a State College criminal defense lawyer since 2004.  His law office, JD Law, P.C., is located in downtown State College, within walking distance of the University Park Campus of Penn State University.  If you or someone you know has been charged with a DUI or other criminal offense, contact JD Law at (814) 954-1094 and schedule a FREE CONSULTATION.

Tuesday, August 28, 2012

Back To School - Focus on Bus Safety

While the last days of summer fade away and a new school year begins, teachers across the state are either writing or implementing their first lesson plans.  Often these lessons plans include a review of subjects that students learned the previous year but may have forgotten.  As drivers sharing the roadway with the school busses that will transport these students, we too can use a refresher course on the traffic laws for sharing the road with school busses.  Section 3345(a) of the Pennsylvania Motor Vehicle Code, titled Meeting or Overtaking School Bus, explains these laws in detail.

Stopping for a School Bus
According to Section 3345(a) of the Pennsylvania Motor Vehicle Code, when either following or approaching a school bus from any direction, a motorist must stop at least 10 feet from a school bus which has its red lights flashing and stop arm extended.  The only exception to this rule is if the roadway is separated by a divider, such as a concrete divider or grass median.  With this exception is the expectation for the driver to remain alert for any students who may be entering or exiting the bus to cross over the divider.  There is some confusion as to whether or not a turning lane is considered a divider in this scenario.  The answer is no.  A good example of this type of roadway is College Avenue in State College, which is a four-lane road that also has a turning lane. Although there are more businesses than residences on certain portions of this road, it is well travelled by school busses.  A motorist travelling in any of these lanes must come to a complete stop when a nearby school bus has its red lights flashing and stop arm extended. 

Passing a School Bus
It is also very important to remember that at no point while a school bus is stopped with its red lights flashing and stop arm extended may a motorist pass a school bus.  Section 3345(a.1) of the Pennsylvania Motor Vehicle Code permits a school bus driver to file a written report of any violation of 3345(a) that he or she may observe.  Simply stated, just because a motorist does not see flashing police lights immediately after meeting or overtaking a school bus, does not mean that he or she will not be cited and penalized.

Consequences for Violating the Law
Whether a driver receives a citation immediately after an alleged violation or through the mail, he or she must enter a plea within ten days.  If a driver decides to enter a plea of guilty, the penalties for this violation include a $250 fine, five points on his or her driving record, and a 60-day license suspension.  If a driver decides that he or she would like to have a hearing on the matter, the driver must enter a not guilty plea and post $50.00 in collateral.  Shortly after doing so, the court will issue a summary trial notice.  For a situation in which a school bus driver filed a report, an attorney may be able to argue at the summary trial that the driver’s report was not credible and therefore the motorist must be found not guilty.  A good course of action for any motorist who receives a traffic citation is to speak with an experienced attorney to find out how the law applies in his or her situation.  The best course of action for all motorists is to familiarize themselves with the Motor Vehicle Code as it applies to school busses and the safety of our children.

Jason S. Dunkle has been a State College criminal defense lawyer since 2004.  His law office, JD Law, P.C., is located in downtown State College, within walking distance of the University Park Campus of Penn State University.  If you or someone you know has been charged with a DUI or other criminal offense, contact JD Law at (814) 954-1094 and schedule a FREE CONSULTATION

Sunday, August 26, 2012

Possible Change to Self-Defense Jurisprudence on Horizon?

The Pennsylvania Supreme Court recently considered an appeal that required them to review self-defense in Pennsylvania.  While the case was a straightforward application of the current self-defense law, some judges not-so subtly stated that they may be reconsider whether the defense or the prosecution should bear the burden of proving self-defense in an assault case.

Commonwealth v. Mouzon involved a man that went to a Philadelphia bar, approached two women, but, after the defendant's advances were rejected by the women, the defendant not only called the women inappropriate names, he followed them throughout the establishment and threatened to kill them.  At some point, a male came to the aid of the women and struck the defendant several times.  The defendant then pulled a loaded gun from his waistband causing the assailant to raise his hands and take a few steps backwards.  Despite the fact that the assailant had stopped his attack, the defendant shot the assailant in the face and a second gunshot struck an innocent bystander.  The assailant died a few days later.  The defendant was charged with homicide, and, at trial, the defense claimed that the defendant acted in self-defense.  

Review of Case
 The Pennsylvania Supreme Court ultimately stated that the defendant could not assert a self-defense argument in this case because he was the initial instigator.  The court noted that man's attack on the defendant was not an isolated incident but was instead the product of the defendant's actions in stalking and threatening the women.  The man was simply acting in a chivalrous manner to protect the women.  Since the defendant instigated the situation that led to the attack on him, the court held that he could not legally have acted in self-defense.

Self-Defense - Who Bears Burden of Proof
The current self-defense law does not require the defendant to prove that his acted in self-defense.  Instead, the defendant must present some evidence of self-defense, through the testimony of his own witnesses or even the prosecution witnesses, and the prosecution must then prove beyond a reasonable doubt that the defendant was not acting in self-defense.  The primary issue is that the prosecution bears the burden is disproving self-defense after it has become a viable defense issue.

Putting the burden upon the Commonwealth to disprove self-defense was the law in Pennsylvania until the mid-1970's.  Prior to the change, the defense was required to prove self-defense by a preponderance of the evidence, so the defense side was required to present the evidence to evidence that the defendant's actions were justified.

Is Court Looking to Change Self-Defense Law in Pennsylvania?
The court in Mouzon mentioned a few times that it was significant that the defendant did not testify to support his claim of self-defense to evidence that he was in fear of death or serious bodily injury when he shot the decedent.  The court noted how difficult it was for a court to consider whether or not the defendant was in fear of death or serious bodily injury when the defendant didn't testify.  In a footnote, the author of the opinion wrote:
"This author would note that this case illustrates the wisdom of the common law rule placing the burden upon the defendant to prove self-defense. Although the defense ultimately is subject to objective evaluation, the core is the defendant's “reasonable belief.” That is a matter known peculiarly to the defendant, and there is no logical reason such an actor-sensitive defense should be permitted to arise from counsel's speculative inferences from the testimony of others."
It is clear that the judge that wrote the majority opinion is basically inviting the prosecution to bring a challenge to how self-defense law is applied in Pennsylvania.  The opinion noted that the court could not consider changing the law in this case and shifting the burden of proof to the defendant because the issue had not been raised.  While the court could not consider changing the self-defense law in this case, the author of the opinion clearly invited the prosecution to bring such a challenge in the future.  One judge wrote a separate opinion that noted that the possible change in self-defense law was "clearly not before us, and such dicta does not necessarily reflect the views of the individual justices of this Court."  I expect that self-defense cases will soon be working their way through the appellate courts to give the Pennsylvania Supreme Court to opportunity to consider this issue within the next few years.

Jason S. Dunkle has been a State College criminal defense lawyer since 2004.  His law office, JD Law, P.C., is located in downtown State College, within walking distance of the University Park Campus of Penn State University.  If you or someone you know has been charged with a DUI or other criminal offense, contact JD Law at (814) 954-1094 and schedule a FREE CONSULTATION

Saturday, August 25, 2012

Prosecutor Loses Conviction Because of Outrageous Conduct

Right to an Impartial Jury
A person's right to a fair and impartial trial is protected by both the U.S. Constitution and the Pennsylvania Constitution.  Generally speaking, a criminal case is a battle between the prosecution and the defense, and the judge's role is to act as a referee to make sure that both sides play fair and in accordance with the rules.  The prosecutor's role in a trial is to prevent evidence that convinces a jury beyond a reasonable doubt that the defendant committed the alleged violation.  In some situations, the prosecutor does not play within the rules, despite repeated admonishments from the judge, and such behaviors, called prosecutorial misconduct, can result in the dismissal of charges.  

In Commonwealth v. Culver, the Superior Court recently considered a case in which the trial court found that the assistant district attorney had engaged in numerous instances of prosecutorial misconduct and that the misconduct had so tainted the trial that the defendant was entitled to a new trial.  In the case, the experienced criminal defense attorney raised timely objections to the prosecutor's behavior, and the judge even sustained the objections and admonished the prosecutor, but the prosecutor simply failed to listen.

Outrageous Behavior From the District Attorney
It was claimed that the assistant district attorney repeatedly invaded the personal space of the defense lawyer and the defendant while the prosecutor pointed his finger at them.  The appellate court characterized the actions as "menacing behavior."  
The assistant district attorney argued that he did not raise his voice, yell, or otherwise act inappropriately, and the prosecutor also claimed that the trial judge's description of the prosecutor's behavior was fabricated.  Amusingly, the Superior Court stated that the assistant district attorney's behavior at oral argument was "consistent with the account of his behavior at trial as described by the trial court," meaning that the prosecutor acted just as inappropriately before the appellate court as he had before the trial court.  The Superior Court also stated that his "volume and tone of his voice during oral argument were inappropriate for an appellate courtroom, as they would have been in any legal forum."  

The prosecutor also told the jury during his opening statement that he had spoken with an expert witness about a particular issue, but, during the trial, it came to light that the prosecutor had NOT in fact spoken with the witness as he had claimed.  In closing argument, the assistant district attorney again mischaracterized what he had done, which led to a defense objection that was sustained by the judge.  

The Superior Court also stated that the prosecutor had committed prosecutorial misconduct when he repeatedly told the jury that the defendant was a liar.  The assistant district attorney called the defendant “probably the most unreliable, unbelievable person that you are ever going to come across," and he insinuated that the defendant was a "compulsive or pathological liar."  The Court stated that "it was particularly egregious" to imply that the defendant was psychologically unable to be truthful. 

Importance of Having Experienced Defense Counsel
The assistant district attorney tried to claim that the Superior Court could not consider some of the instances of prosecutorial misconduct because the defense attorney did not object to every single instance.  Generally, if the defense attorney does not raise a timely objection to perceived errors, then the court will later hold that the issues were waived and thereby cannot be considered.  In this case, the Superior Court noted that the defense attorney had objected to many of the instances of misconduct, and the defense attorney had adequately preserved the issue.  The waiver doctrine shows why it is so important to have a defense attorney that is knowledgeable and experienced so that appropriate objections are raised to protect the rights of the client.  I have used hearsay objections in various Underage Drinking cases to keep such testimony from being admitted at a hearing and thereby protect the client.  I have also represented a client in a PCRA action in which the attorney had failed to adequately review the file and thereby failed to file a motion to dismiss charges when the prosecution's own evidence did not support some of the charges.  

Jason S. Dunkle has been a State College criminal defense lawyer since 2004.  His law office, JD Law, P.C., is located in downtown State College, within walking distance of the University Park Campus of Penn State University.  If you or someone you know has been charged with a DUI or other criminal offenese, contact JD Law at (814) 954-1094 and schedule a FREE CONSULTATION

Friday, August 24, 2012

Will District Attorneys Use the Sentencing Enhancement for DUI Offenders That Had a Juvenile in Car?

As discussed in a prior blog post, on July 9, 2012, an amendment to the DUI law became effective that increased both the grading and the penalties for a DUI charge if a “minor under 18 years of age was an occupant in the vehicle when the violation occurred.”  Basically, if a person charged with a DUI has a juvenile in the vehicle, then the district attorney has to make a decision whether or not to seek the increased penalties for the DUI offense.  People probably assume that a district attorney would always seek the maximum penalty possible in such a situation, but, as with almost any decision, there are benefits but also costs that must be considered. 

What Are the Costs?
The increased DUI penalties come with the cost of giving the DUI defendant the right to a jury trial.  Generally, most first and second offense DUI defendants do not have the right to have the case heard by a jury but instead are only entitled to a trial before a judge.  Most experienced DUI defense attorneys would prefer to have a trial by jury as opposed to a trial by judge.  A jury trial increases the amount of time and thereby increases the expense of prosecution of a DUI case for the district attorney.  One could respond that the possibility of a jury trial is not much of a cost since the majority of criminal cases do not make it to a trial as they are resolved via a plea agreement between the prosecution and the defense.  However, when the district attorney seeks increased penalties, a defendant is more likely to proceed to a trial to avoid those penalties, and the DUI defendant would prefer to “roll the dice” at a trial before a jury.  The jury trial issue would not have an impact on second offense DUI defendants charged with having the highest rate of alcohol or three time DUI offenders as those persons are already entitled to a jury trial. 

What Are the Benefits?
Simply stated, the amendment to the DUI law gives the district attorney more power to control a sentence that is imposed on a DUI defendant.  The problem with the amendment is that the power given to the district attorney is relatively minor as the amendment does not impose sentences that are much greater than the mandatory minimum sentences already required for DUI offenses.  For example, if the enhancement is imposed on a first offense of DUI, the mandatory fine is $1,000.00 and completion of 100 hours of community service is required.  A first offense DUI in the third or highest range of penalties already requires a mandatory minimum fine of $1,000.00.  If the juvenile passenger enhancement is imposed on a second offense, the mandatory sentence includes a $2,500.00 fine and not less than 1 month nor more than 6 months incarceration.  Without seeking the sentencing enhancement, a two-time DUI offender in the middle range of penalties already faces a mandatory minimum of 1 month incarceration, and a two- time DUI offender in the highest range of penalties faces a 3 month minimum period of incarceration.  In some situations, the penalties imposed after invoking the juvenile passenger enhancement would result in increased mandatory penalties, but, in many other situations, the penalties are the same and sometimes even less than the mandatory minimum penalties already imposed.  Therefore, the district attorney would only receive a benefit when invoking the enhancement in certain DUI cases.

Will It Be Used?
I believe that the DUI sentencing enhancement for having a minor passenger in the vehicle was created more by Pennsylvania politicians to appease constituents than actually punish violators of the law and deter such conduct.  As discussed above, the amendment does not substantially increase the penalties for DUI offenses.  Also, district attorneys routinely already use other charges, such as Endangering the Welfare of a Child or Reckless Endangerment, in DUI cases in a minor was an occupant.  Therefore, the current DUI enhancement was not needed to give the district attorney another way to punish DUI offenders.  The district attorney will have to consider the costs and benefits associated with invoking the DUI sentencing enhancement.  Generally speaking, an experienced DUI defense attorney would much rather proceed to a jury trial rather than a bench trial.

Jason S. Dunkle has been a State College criminal defense lawyer since 2004.  His law office, JD Law, P.C., is located in downtown State College, within walking distance of the University Park Campus of Penn State University.  If you or someone you know has been charged with a DUI or other criminal offenese, contact JD Law at (814) 954-1094 and schedule a FREE CONSULTATION