Com. v. Crumpler, L.
1742 MDA 2017
| Pa. Super. Ct. | Nov 2, 2018Background
- Appellant Lamar Crumpler, an inmate at Franklin County Jail, was tried and convicted by a jury of aggravated assault (against an officer) and related charges for throwing a plastic chair at Officer Shawn Keebaugh.
- Keebaugh ordered inmates to remain quiet while medication was distributed; Crumpler refused to leave the shower and became increasingly belligerent.
- After a confrontation in which Crumpler threatened Keebaugh and kicked a shower door (which grazed Keebaugh), Keebaugh escorted Crumpler back to his cell.
- In the cell, Crumpler allegedly looked Keebaugh in the eye, threatened him, and then grabbed and threw a plastic chair at Keebaugh, who blocked it with his arm and suffered a scratch and marks.
- Crumpler asserted he dropped the chair only after being sprayed in the eyes with pepper spray; Keebaugh testified Crumpler threw the chair.
- Crumpler appealed, arguing (1) insufficient evidence that he intended to cause bodily injury (and took a substantial step) and (2) the verdicts were against the weight of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency: whether evidence supported attempt to cause bodily injury to an officer | Commonwealth: testimony shows threats, kicking door, then throwing chair — intent and substantial step proven | Crumpler: he only dropped a lightweight chair after being pepper-sprayed; chair could not cause injury | Court affirmed: evidence (threats, conduct, chair thrown) permitted jury to find intent and a substantial step |
| Weight of the evidence: whether verdict shocks the conscience | Commonwealth: jury credibility determinations reasonable given record | Crumpler: testimony and inmate corroboration show chair was dropped after spray; chair too light to injure | Court affirmed trial court’s exercise of discretion; verdict did not shock judicial conscience |
Key Cases Cited
- Commonwealth v. Doughty, 126 A.3d 951 (Pa. 2015) (sufficiency review standard and circumstantial evidence may sustain conviction)
- Commonwealth v. Jacoby, 170 A.3d 1065 (Pa. 2017) (sufficiency challenge is a question of law; de novo review)
- Commonwealth v. Rivera, 983 A.2d 1211 (Pa. 2009) (appellate scope for weight-of-the-evidence review; defer to trial court’s discretion)
- Commonwealth v. Champney, 832 A.2d 403 (Pa. 2003) (weight-of-the-evidence reversal only when verdict shocks one’s sense of justice)
- Commonwealth v. Davidson, 860 A.2d 575 (Pa. Super. 2004) (articulation of "shocks the judicial conscience" standard)