Com. v. Benefield, E.
Com. v. Benefield, E. No. 1221 EDA 2016
Pa. Super. Ct.Apr 21, 2017Background
- Appellant Eric Benefield was arrested after blocking the tow of his BMW that had been designated abandoned for registration/inspection violations; he resisted, refused handcuffs, and was tased.
- He pled guilty, with counsel, to obstructing administration of law or other governmental function, 18 Pa.C.S.A. § 5101, under a negotiated plea.
- The trial court accepted his guilty plea and, after a Faretta/Grazier hearing, allowed him to proceed pro se on appeal; sentence was time served with immediate parole.
- On appeal, Benefield filed a court-ordered concise statement that failed to identify legal bases sufficiently; many claims were incoherent or frivolous.
- The appellate record omitted the trial transcript, preventing meaningful review.
- The appellant’s substitute brief was noncompliant and incoherent; the court dismissed the appeal and found all issues waived or frivolous.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction to convict/appeal | Benefield asserted lack of jurisdiction (vague/conclusory) | Commonwealth maintained conviction and procedure were proper | Waived: concise statement failed to state legal basis; claims frivolous |
| Adequacy of appellate record (missing transcript) | Benefield relied on filings in record and other materials | Commonwealth: record incomplete; transcript necessary for review | Record defective; without transcript appellate review impossible; issues not considered |
| Compliance with appellate briefing rules | Benefield submitted an "averment" as brief with incoherent claims | Commonwealth referenced Pa.R.A.P. requirements | Noncompliant brief; appeal may be dismissed under Pa.R.A.P. 2101; dismissal affirmed |
| Credibility of supplemental materials (frivolous filings) | Benefield included irrelevant/frivolous materials (e.g., IRS filings, conspiracy assertions) | Commonwealth treated these as irrelevant and undermining | Court rejected these materials as enhancing claims; they do not support relief |
Key Cases Cited
- Grazier v. Commonwealth, 713 A.2d 81 (Pa. 1998) (standards for accepting waiver of counsel and proceeding pro se)
- Robert Half Int'l, Inc. v. Marlton Technologies, Inc., 902 A.2d 519 (Pa. Super. 2006) (appellate review standards for questions of law; de novo review)
- Commonwealth v. Preston, 904 A.2d 1 (Pa. Super. 2006) (matters not of record generally cannot be considered on appeal)
- Commonwealth v. Lyons, 833 A.2d 245 (Pa. Super. 2003) (court may quash or dismiss appeals for failure to comply with appellate rules)