Com. v. Brown, I., 1997 WDA 2015

Isaiah Brown pled guilty to robbery, burglary, criminal conspiracy, theft by unlawful taking, and two counts of receiving stolen property after a November 2014 home invasion that involved a firearm, victims being forced to produce money and car keys, and a high‑speed chase ending in a crash and arrests.
At plea, the Commonwealth summarized witnesses and confessions corroborating the incident.
On November 2, 2015, the court sentenced Brown to 18 to 56 months’ imprisonment (mitigated range) for robbery with 3 years’ probation to follow; other counts received no additional penalty.
Brown filed a timely post‑sentence motion and appeal challenging the discretionary aspects of his sentence, claiming the court focused only on offense seriousness and juvenile history and failed to consider mitigating factors under 42 Pa.C.S. § 9721(b).
The trial court had a pre‑sentence investigation (PSI) and expressly referenced Brown’s mitigation (acceptance of responsibility, cooperation, lack of gun possession, mental health, family history, strong school performance) but also noted juvenile gun‑related adjudications when denying a below‑guideline county sentence and imposing the mitigated range term.

Issue	Appellant's Argument	Commonwealth's Argument	Held
Whether the sentencing court abused discretion by focusing almost exclusively on offense seriousness and juvenile record and failing to consider all § 9721(b) factors	Brown argued the court gave undue weight to the offense and juvenile history and did not sufficiently consider mitigating factors (mental health, family history, rehabilitation needs)	The court preserved record, had a PSI, considered mitigating factors, and reasonably relied on offense gravity and juvenile gun adjudications to deny a county sentence	No abuse of discretion; sentence affirmed (court considered relevant factors and imposed a mitigated‑range sentence)

Griffin, 65 A.3d 932 (Pa. Super. 2013) (four‑part test to invoke appellate review of discretionary sentencing claims)
Edwards, 71 A.3d 323 (Pa. Super. 2013) (definition of a "substantial question" for sentencing appeals)
Trimble, 615 A.2d 48 (Pa. Super. 1992) (claim that court focused solely on offense seriousness can present a substantial question)
Clarke, 70 A.3d 1281 (Pa. Super. 2013) (where PSI is available, court is presumed to have considered relevant information)
Devers, 546 A.2d 12 (Pa. 1988) (trial court’s possession of facts in PSI supports presumption they were applied in sentencing)