Com. v. Corprew, Q.
1861 WDA 2015
| Pa. Super. Ct. | Oct 6, 2016Background
- On March 12–13, 2011, Quinton Corprew and victim Michael McGinnis argued at a bar after both had been drinking; they left the bar and agreed to "go around the building and fight."
- Witness David Herring saw the confrontation outside; McGinnis was unarmed (denied any weapon) though had a prior history of violence and had allegedly threatened Corprew with a pool cue earlier.
- Corprew pulled a lock‑blade knife and stabbed McGinnis seven times; McGinnis sustained multiple life‑threatening stab wounds and rib/scapular fractures requiring emergency trauma care.
- Corprew, a convicted felon on parole (for whom possession of a knife was a parole violation), claimed self‑defense at trial, asserting McGinnis rushed and bear‑hugged him such that deadly force was necessary.
- A jury convicted Corprew of aggravated assault (serious bodily injury), aggravated assault (bodily injury with a deadly weapon), simple assault, and recklessly endangering another person; he was sentenced to 10–20 years.
- Procedural history: direct appeal affirmed in 2012; PCRA filed and remanded leading to reinstated direct appeal rights; Corprew appealed nunc pro tunc and the Superior Court affirmed on appeal (Oct. 6, 2016).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence given self‑defense claim | Commonwealth: its evidence disproved self‑defense beyond a reasonable doubt | Corprew: acted in self‑defense because McGinnis was violent, rushed and bear‑hugged him; stabbing was necessary | Court: affirmed convictions — jury could reject self‑defense; Corprew escalated and used unreasonable deadly force |
Key Cases Cited
- Commonwealth v. Mouzon, 53 A.3d 738 (Pa. 2012) (self‑defense must be supported by some evidence before in issue; defendant must be free from provocation)
- Commonwealth v. Torres, 766 A.2d 342 (Pa. 2001) (once justification raised, Commonwealth must disprove it beyond a reasonable doubt)
- Commonwealth v. McClendon, 874 A.2d 1223 (Pa. Super. 2005) (means for Commonwealth to negate self‑defense: unreasonable belief, provocation, or safe retreat available)
- Commonwealth v. Smith, 97 A.3d 782 (Pa. Super. 2014) (reasonable belief test has subjective and objective components)
- Commonwealth v. Alvin, 516 A.2d 376 (Pa. Super. 1986) (use of deadly force unavailable to one who provoked or continued the difficulty)
- Commonwealth v. Williams, 959 A.2d 1252 (Pa. Super. 2008) (sufficiency claims are waived if not specified in Pa.R.A.P. 1925(b) statement)