Com. v. Eastman, N., Com. v. Eastman, N. No. 893 MDA 2016

On August 22, 2014, Nancy Jeanne Eastman was stopped near a DUI checkpoint after making a U-turn and stopping with four-way flashers on; officers smelled marijuana and observed bloodshot, glassy eyes.
Trooper Gregory Strayer administered standardized field sobriety tests; video from his dash camera was admitted at trial.
Trooper testified Eastman displayed 6/6 HGN indicators, 6/8 walk-and-turn clues, and 3/3 one-leg-stand clues; she appeared confused and slow in speech.
Eastman consented to a blood draw showing Delta-9 THC and amphetamines above legal limits and some alcohol below the legal limit; she was charged with multiple DUI counts and possession of a small amount of marijuana.
At a bench trial on January 20, 2016, Eastman was convicted under 75 Pa.C.S. § 3802(d)(3) (combined influence of alcohol and drugs) and acquitted of other counts.
She received a sentence of 72 hours to six months, with credit for time served and immediate parole; her post-sentence motion claiming the verdict was against the weight of the evidence was denied and she appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the verdict was against the weight of the evidence (i.e., Commonwealth failed to show Eastman was incapable of safely driving)	Eastman: Trooper’s testimony showed she was cooperative, could produce license/insurance, did not slur speech or fall — evidence insufficient to prove incapacity	Commonwealth: Video, trooper testimony, FST results, observed signs of impairment, and blood results (THC and amphetamines) support conviction	Court affirmed: trial court, as fact-finder, reasonably credited Commonwealth’s evidence and did not abuse its discretion in denying the weight claim

Commonwealth v. Gonzalez, 109 A.3d 711 (Pa. Super. 2015) (finder of fact may accept or reject testimony and determine credibility)
Commonwealth v. Clay, 64 A.3d 1049 (Pa. 2013) (standards governing weight-of-the-evidence claims and trial court discretion)
Commonwealth v. Widmer, 744 A.2d 745 (Pa. 2000) (trial court’s role in weighing evidence and granting new trials for verdicts against the weight of the evidence)
Commonwealth v. Brown, 648 A.2d 1177 (Pa. 1994) (new trial appropriate when verdict shocks one’s sense of justice)
Commonwealth v. Diggs, 949 A.2d 873 (Pa. 2008) (denial of weight-based new trial is among least assailable rulings)
Commonwealth v. Farquharson, 354 A.2d 545 (Pa. 1976) (appellate deference to trial court findings on weight claims)