Com. v. Cramer, W.
Com. v. Cramer, W. No. 942 MDA 2016
| Pa. Super. Ct. | Mar 28, 2017Background
- On August 31, 2014, inmate William Amos Cramer attacked corrections officer Francisco Charriez at SCI‑Coal, cutting the officer with a razor and inflicting serious wounds; Charriez survived but developed PTSD.
- After the incident Cramer was transported and interviewed; he reportedly said he premeditated the attack, waited, grabbed Charriez from behind, and tried to cut his throat with a razor to kill him, then discarded the weapon.
- A criminal complaint charged Cramer with multiple offenses; a later Information (filed five months before trial) added two aggravated‑assault counts that Cramer says he was not served with.
- At trial the jury convicted Cramer of eight counts, including aggravated assault (multiple subsections), assault by a life prisoner, attempted murder, possession of an instrument of crime, and prohibited offensive weapons.
- Cramer was sentenced to an aggregate 20–40 years consecutive to his life sentence, and appealed arguing (1) lack of due process/notice of the added charges and (2) insufficiency of the evidence to support convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Notice of added charges / Due process | Commonwealth: Information included the added counts; clerk must furnish copy only on request; Cramer had adequate notice from other charging documents | Cramer: Additional aggravated‑assault counts in the Information were not served; he lacked notice and preparation, requiring a new trial | Court: No merit — added counts were in the Information filed five months before trial; Cramer made no showing he requested a copy; other charges provided adequate notice |
| Sufficiency of the evidence (intent, serious bodily injury, weapon) | Commonwealth: evidence (victim testimony, eyewitness who saw discard, Cramer’s custodial admissions) supports convictions including intent to kill and possession/use of a razor | Cramer: He recanted custodial statements at trial, claimed self‑defense/provocation, lack of video, no weapon recovered, injuries were minor — insufficient to prove intent and serious bodily injury beyond reasonable doubt | Court: Evidence sufficient — jury could credit custodial confession and Commonwealth witnesses; circumstantial proof and injuries supported convictions; appeal rejects reweighing credibility |
Key Cases Cited
- Commonwealth v. Cruz, 71 A.3d 998 (Pa. Super. 2013) (standard for reviewing sufficiency of the evidence)
- Commonwealth v. Gibbs, 981 A.2d 274 (Pa. Super. 2009) (circumstances may sustain conviction and appellate standard on sufficiency)
- Commonwealth v. Melvin, 103 A.3d 1 (Pa. Super. 2014) (fact‑finder may believe all, part, or none of testimony)
- Commonwealth v. Rabold, 920 A.2d 857 (Pa. Super. 2007) (credibility determinations are for the jury)
- Commonwealth v. W.H.M., 932 A.2d 155 (Pa. Super. 2007) (disagreement with witness credibility is a weight, not sufficiency, claim)
- Commonwealth v. Dale, 836 A.2d 150 (Pa. Super. 2003) (upholding attempted murder/aggravated assault convictions for throat‑cutting with a razor)