Com. v. Coffee, T.
Com. v. Coffee, T. No. 54 EDA 2016
| Pa. Super. Ct. | May 16, 2017Background
- June 2013: Multiple Craigslist “for sale/trade” meetings were arranged using an ad tied to Thomas Coffee’s email/phone; several victims were robbed at gunpoint during these meetings.
- On June 8, 2013, Ben Booker was robbed; a .40 caliber handgun and ammunition were stolen. Forensic testing later tied that .40 caliber weapon to the June 21 shooting.
- On June 21, 2013, Daniel Cook responded to the Craigslist ad to buy an ATV; he was shot multiple times (one wound to the back penetrating the heart) and died. Three .40 caliber casings were recovered.
- Phone, digital, and physical evidence linked Coffee to the ad, the contact number, proximity to the shooting (cell-tower/location data), a photo of the ATV on Coffee’s phone, deletion of the ad after the shooting, and attempted destruction/removal of Coffee’s SIM card.
- Coffee was arrested, tried jointly on consolidated dockets, convicted of first‑degree murder and related offenses, and sentenced to life plus 50–100 years; he appealed challenging sufficiency, weight of the evidence, and a trial-evidence ruling.
Issues
| Issue | Appellant's Argument | Commonwealth's/Trial Court's Position | Held |
|---|---|---|---|
| Sufficiency of evidence for 1st‑degree murder | Evidence did not prove Coffee was the shooter or had specific intent/premeditation | Physical, forensic, cell‑phone, and consciousness‑of‑guilt evidence established he shot Cook with the stolen .40 and had intent to kill | Conviction affirmed — evidence sufficient for first‑degree murder |
| Weight of the evidence (new trial) | Verdict was based on speculation; robbery gone wrong theory more consistent | Jury credibility findings and overwhelming forensic/circumstantial proof supported verdict | Trial court did not abuse discretion; weight claim denied |
| Impeachment of Detective Dove with unrelated misconduct | Coffee sought to impeach Dove with allegations of unrelated misconduct to attack investigation credibility | Trial court excluded as cumulative, prejudicial, and not probative of case facts; evidence wouldn’t change outcome given overwhelming proof | Waived on appeal; alternatively, exclusion harmless and proper |
Key Cases Cited
- Commonwealth v. Thomas, 988 A.2d 669 (Pa. Super. 2009) (standard for sufficiency review)
- Commonwealth v. Montalvo, 956 A.2d 926 (Pa. 2008) (elements of first‑degree murder)
- Commonwealth v. Manley, 985 A.2d 256 (Pa. Super. 2009) (firing into area of vital organs can establish intent to kill)
- Commonwealth v. Galvin, 985 A.2d 783 (Pa. 2009) (weight‑of‑the‑evidence standard)
- Commonwealth v. Shaffer, 40 A.3d 1250 (Pa. Super. 2012) (appellate scope when trial court rules on weight claim)
- Commonwealth v. Clay, 64 A.3d 1049 (Pa. 2013) (limits on trial court discretion re: weight claims)
- Commonwealth v. Andrulewicz, 911 A.2d 162 (Pa. Super. 2006) (trier of fact may accept or reject witness testimony)