Com. v. Ferguson, Q., Com. v. Ferguson, Q. No. 1067 EDA 2015

Decedent was shot during a street altercation near businesses on South 52nd Street; surveillance video (no audio) captured the incident. Appellant (Ferguson) was identified as the shooter and was detained at the scene by an off-duty police officer.
Ferguson testified he was on crutches, had been threatened repeatedly by the intoxicated victim, believed the victim was reaching for a gun, and shot in (claimed) self-defense after instructing an associate to give him his firearm.
The jury acquitted Ferguson of first- and third-degree murder and conspiracy, but convicted him of voluntary manslaughter and two firearm offenses; the trial court imposed an aggregate 9.5–19 year term plus probation. Ferguson appealed.
Claims on appeal: (1) insufficient evidence to disprove self-defense for voluntary manslaughter; (2) trial court erred by admitting a 2008 prior firearm possession incident in rebuttal (propensity/prejudice); (3) trial court erred by allowing cross-examination of a potential character witness about a juvenile adjudication, causing defense to decline offering the witness.
The trial court and this Court reviewed the surveillance, testimony (including Ferguson’s), and stipulations; the jury’s credibility determinations and the court’s evidentiary rulings were central to the outcome.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency: Did Commonwealth disprove self-defense such that voluntary manslaughter is supported?	Commonwealth: jury could reject Ferguson’s self-defense claim based on video and circumstances; proved killing was not justified.	Ferguson: claimed he reasonably (subjectively and objectively) believed deadly force necessary because victim reached for gun.	Held: Evidence sufficient; jury could find belief unreasonable or that Ferguson provoked/introduced deadly force; conviction affirmed.
Admission of prior firearm incident in rebuttal	Commonwealth: prior possession was admissible to rebut Ferguson’s testimony that he avoided carrying guns due to disability (credibility).	Ferguson: prior incident was irrelevant propensity evidence and unduly prejudicial.	Held: Admissible for impeachment/rebuttal of Ferguson’s testimony; limiting instruction given; no abuse of discretion.
Cross-examination about juvenile adjudication of defendant	Commonwealth: could impeach character-witness testimony about reputation by asking about prior adjudication that would be admissible if adult conviction.	Ferguson: juvenile adjudication is not a conviction and was stale, so impeachment was improper and prejudicial.	Held: Trial court did not abuse discretion; juvenile adjudication for violent offense admissible to impeach reputation testimony; no relief.

Commonwealth v. Hansley, 24 A.3d 410 (Pa. Super. 2011) (standard for sufficiency review and evaluation of all evidence in light most favorable to verdict winner)
Commonwealth v. Smith, 710 A.2d 1218 (Pa. Super. 1998) (voluntary manslaughter defined where defendant holds an unreasonable belief in justification)
Commonwealth v. Mouzon, 53 A.3d 738 (Pa. 2012) (reasonable-belief element of self-defense has subjective and objective components)
Commonwealth v. Sepulveda, 55 A.3d 1108 (Pa. 2012) (Commonwealth may negate self-defense by disproving reasonable belief of imminent danger)
Commonwealth v. Dillon, 925 A.2d 131 (Pa. 2007) (standard for appellate review of evidentiary admissibility/abuse of discretion)