Com. v. Garcia, A., Com. v. Garcia, A. No. 1874 EDA 2015

On Nov. 30, 2013, Casey Massey was shot in an alley in Philadelphia and later died; he told police in the ambulance that someone grabbed his headphones from behind and he felt one set of hands but saw no faces.
Police obtained surveillance video of the alley; a confidential informant identified a figure who might be Arkel Garcia.
On Dec. 7, 2013, plainclothes officers brought Garcia to the Homicide Unit; he was not handcuffed, signed in as a witness, sat in the front room, and remained at the station overnight; detectives interrogated him the next day.
On Dec. 8, after food, breaks, Miranda warnings, and written and video statements, Garcia admitted accompanying two others, said "Leek" fired a .380 three times, and provided identifying information; police later arrested him.
At trial the Commonwealth relied on Garcia’s inculpatory statements, the video, boot similarity, cartridge caliber, and a prison call; defense offered alibi witnesses (mother and Aneesah Young) with credibility impeached.
Jury convicted Garcia of second-degree murder, robbery, and carrying a firearm without a license; trial court denied suppression and mistrial motions; Superior Court affirmed.

Issue	Plaintiff's Argument (Commonwealth)	Defendant's Argument (Garcia)	Held
Sufficiency of evidence	Evidence (statements, video, boot evidence, caliber match, prison call) supports robbery, felony-murder, and unlicensed firearm	Evidence insufficient; no physical proof he was shooter or took property; testimony speculative	Affirmed: evidence sufficient to sustain convictions
Weight of the evidence	Verdict supported; credibility determinations for jury	Verdict against weight; alibi witnesses and lack of physical evidence	Waived (not raised below); merits would fail — no abuse of discretion denying new trial
Prosecutorial misconduct (closing)	ADA’s comments about alibi witness’s age and bias were fair comment on credibility	ADA made improper references implying uncharged sexual misconduct; motion for mistrial warranted	One passing improper remark found but harmless; mistrial denial affirmed
Suppression — voluntariness / due process of statements	Statements voluntary under totality (Miranda given; breaks, food, sleep; no coercive tactics)	Statements involuntary due to overnight detention, no counsel/family access, coercive delay	Affirmed: statements voluntary under totality; suppression denied
Suppression — Fourth Amendment (arrest without probable cause)	N/A at suppression court (not argued there)	Detention became functional arrest in locked interview room without probable cause; statements thus inadmissible	Waived on appeal for failure to raise below; not addressed on merits

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warning principles governing custodial interrogation)
Commonwealth v. Lehman, 820 A.2d 766 (Pa. Super. 2003) (sufficiency review standard)
Commonwealth v. DiStefano, 782 A.2d 574 (Pa. Super. 2001) (consideration of all evidence received on appeal)
Commonwealth v. Cooper, 941 A.2d 655 (Pa. 2007) (circumstantial evidence can sustain conviction)
Commonwealth v. Perez, 845 A.2d 779 (Pa. 2004) (totality-of-circumstances test for voluntariness of statements)
Commonwealth v. Bryant, 67 A.3d 716 (Pa. 2013) (voluntariness factors and lengthy detention not dispositive)
Commonwealth v. Clay, 64 A.3d 1049 (Pa. 2013) (standard for review of weight-of-evidence claims)
Commonwealth v. Caldwell, 117 A.3d 763 (Pa. Super. 2015) (prosecutorial closing-argument review standard)
Commonwealth v. Allshouse, 36 A.3d 163 (Pa. 2012) (harmless-error doctrine in criminal appeals)