Com. v. Groce, F., Com. v. Groce, F. No. 894 EDA 2016

Groce was arrested after Officer Ken Fazio observed him kicking and stomping on a man who was on the ground at 1800 Madison Street, Philadelphia.
Officer Fazio did not witness the altercation’s inception, did not identify the victim, but testified that both Groce and the other man wore white hoodies.
Groce was charged with and convicted of simple assault (18 Pa.C.S. § 2701) following a non-jury trial on December 18, 2015; sentence imposed March 7, 2016.
On appeal Groce contended the evidence was insufficient because facts supported an inherent claim of self‑defense and the Commonwealth failed to disprove self‑defense beyond a reasonable doubt.
The trial court record contained no evidence supporting a self‑defense claim; Officer Fazio’s testimony described repeated kicking and stomping while the victim was on the ground.
The Superior Court reviewed the sufficiency claim on the merits and declined to remand for a Rule 1925(a) opinion because the record adequately reflected the trial court’s reasoning.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency: Did evidence fail to disprove self‑defense such that conviction must be reversed?	Commonwealth: evidence (officer testimony of repeated kicks/stomps) sufficiently proved simple assault; no evidence supported self‑defense.	Groce: officer did not see the incident start, so facts present an inherent self‑defense claim and Commonwealth must disprove it beyond a reasonable doubt.	Affirmed. No evidence justified self‑defense; even if self‑defense existed earlier, continued kicking/stomping on a prone victim was not immediately necessary and became assault.

Commonwealth v. Watley, 81 A.3d 108 (Pa. Super. 2013) (standard for reviewing sufficiency of the evidence)
Commonwealth v. Torres, 766 A.2d 342 (Pa. 2001) (Commonwealth must disprove self‑defense beyond a reasonable doubt only when some evidence supports the defense)
Commonwealth v. Hood, 872 A.2d 175 (Pa. Super. 2005) (discussing appellate review when trial court does not file a Rule 1925(a) opinion)