Com. v. Anderson, J.
2076 MDA 2016
| Pa. Super. Ct. | Oct 4, 2017Background
- On Nov. 19, 2014 Maurice Geter (decedent), a drug dealer, was shot and later died in Apricot Alley; defendant Jamoni T. Anderson (Appellant) was convicted by a jury of voluntary manslaughter and sentenced to 6–20 years.
- Prior events: Geter made multiple angry calls to a phone carried by Tamir Williams; Geter borrowed a .380 from Shaquan Jones that day and displayed it to a companion (Cuff).
- Williams, Appellant, and friend Raylynnd Aldridge drove to confront Geter after taunting on the phone about stealing a drug customer; Aldridge and Williams had Pena’s phone and answered calls from Geter.
- During the alley encounter witnesses testified that Geter appeared armed, shots were fired, and Appellant fired multiple rounds using a .40-caliber gun with a laser sight; ballistics showed .40-caliber cases from two different guns and a separate .380 was recovered on the scene.
- Appellant testified he fired in fear after seeing Geter point a gun; other witnesses said Appellant later admitted shooting Geter because Geter “stole” his client.
- Trial court convicted Appellant of voluntary manslaughter; he appealed arguing insufficiency and that the Commonwealth’s evidence was unreliable/contradictory.
Issues
| Issue | Commonwealth's Argument | Appellant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient to sustain voluntary manslaughter conviction | Evidence shows Appellant went to confront Geter angry about a stolen customer, carried a gun, fired using a laser sight, and admitted shooting Geter — supports homicide with malice and intent | Commonwealth’s case was unreliable/contradictory; testimony conflicts make any verdict conjectural | Affirmed — evidence, viewed in Commonwealth’s favor, was sufficient; jury could have convicted of first-degree murder but reasonably found voluntary manslaughter |
| Whether contradictions in witness statements rendered the verdict speculative | Multiple witnesses corroborated key facts; credibility/resolution of inconsistencies is for the jury | Inconsistent statements (e.g., about who had guns, sequence of shots) so verdict rests on conjecture | Rejected — inconsistencies affect weight, not sufficiency; jury properly resolved credibility |
Key Cases Cited
- Commonwealth v. Weston, 749 A.2d 458 (Pa. 2000) (upholding voluntary manslaughter conviction where defendant armed himself to confront decedent and fired after confrontation)
- Commonwealth v. Ortiz, 160 A.3d 230 (Pa. Super. 2017) (standard for sufficiency review; view evidence in light most favorable to verdict winner)
- Commonwealth v. Murray, 83 A.3d 137 (Pa. 2013) (elements required for first-degree murder include malice and specific intent to kill)