The Pennsylvania Supreme Court has held that its determination that a jury be informed of the consequences of a verdict of not guilty by reason of insanity not be applied retroactively and, more specifically, not to a case on direct appeal at the time of that decision.
Commonwealth of Pennsylvania v. Geschwendt, 500 Pa. 120, 454 A.2d 991 (1982).
Edward J. Borkowski,
Criminal Law - Retroactivity - Jury Instructions - Consequences of a Verdict of Non Guilty by Reason of Insanity,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol22/iss4/17