Com. v. Edens, W., 732 EDA 2016

Background

On July 25, 2012, Waleed Edens approached his father (the complainant) in front of the father’s house, displayed a gun, told him “I ain’t scared of you,” then shot him three times; the victim identified Edens at the scene.
Edens fled and was arrested by the FBI on September 7, 2012; police later searched his car and residence and recovered ammunition and an empty AK-47 magazine.
A jury convicted Edens of aggravated assault and carrying a firearm on Philadelphia public streets; following a waiver trial the court convicted him of possession of a firearm by an ineligible person.
Sentencing (Nov. 9, 2015): aggregate 12 to 30 years’ imprisonment (including mandatory minimum under 42 Pa.C.S. § 9714 for second-strike aggravated assault), plus five years’ probation; post-sentence motion denied and timely appeal filed.
On appeal Edens challenged (1) weight of the evidence/self-defense, (2) sufficiency of the evidence, (3) evidentiary rulings on prior convictions (victim’s and defendant’s), and (4) discretionary aspects of sentence.

Issues

Issue	Commonwealth's Argument	Edens' Argument	Held
1. Whether guilty verdicts were against the weight of the evidence (self-defense)	Jury and trial court credited Commonwealth witnesses; evidence showed Edens was aggressor and fired after approaching victim; flight indicated guilt	Edens claimed he acted in self-defense because victim was the aggressor, a known violent killer, and he could not safely retreat	Held: No weight claim—verdict not against conscience; Commonwealth disproved self-defense beyond a reasonable doubt (Edens was aggressor and could have retreated)
2. Sufficiency of the evidence to support convictions	Evidence proved elements of aggravated assault, VUFA possession, and public-carry; victim ID, shell casings, recovered ammunition	Edens asserted generally that evidence was insufficient (no developed argument)	Held: Waived for lack of developed argument; no relief granted
3. Admissibility of victim’s and defendant’s prior convictions	Trial court: defendant’s robbery convictions admissible for impeachment (crimen falsi within 10 years of release); victim’s 1990 manslaughter conviction too remote and therefore excluded	Edens wanted victim’s prior manslaughter admitted to show violent propensity and corroborate self-defense; objected to admission of his robbery convictions as propensity evidence	Held: Trial court did not abuse discretion — victim’s 1990 conviction excluded as too remote; Edens’ robbery convictions properly admitted under Pa.R.E. 609 for impeachment
4. Discretionary aspects of sentencing (consecutive/excessive; mitigation)	Commonwealth noted procedural defaults; trial court imposed mandatory minimums and explained sentencing scheme	Edens argued court failed to consider mitigating factors (rehabilitation, family, abuse history) and sentence was excessive	Held: Claim waived for failure to include required Pa.R.A.P. 2119(f) statement; no review of discretionary claim granted

Key Cases Cited

Commonwealth v. Chine, 40 A.3d 1239 (Pa. Super. 2012) (standard for weight-of-the-evidence review)
Commonwealth v. Houser, 18 A.3d 1128 (Pa. 2011) (Commonwealth’s burden to disprove self-defense beyond a reasonable doubt)
Commonwealth v. Mouzon, 53 A.3d 738 (Pa. 2012) (admissibility of victim’s prior convictions when self-defense is asserted)
Commonwealth v. Beck, 402 A.2d 1371 (Pa. 1979) (victim’s prior violent convictions may be admitted to corroborate defendant’s knowledge or to show victim was aggressor)
Commonwealth v. May, 898 A.2d 559 (Pa. 2006) (robbery is crimen falsi; such convictions admissible for impeachment)