Com. v. Haight, R.
458 WDA 2017
| Pa. Super. Ct. | Dec 29, 2017Background
- On Nov. 19, 2016, Ashley Streit (the victim) and Ralph Haight, IV, who lived together and shared a child, had a physical altercation after Haight was intoxicated and Streit attempted to leave with their infant.
- A struggle over a baby car seat occurred; Streit alleged Haight struck her and showed red marks on her face; she called 9‑1‑1 and reported the assault to Trooper Herrick.
- A magisterial district judge convicted Haight of harassment; the conviction was affirmed after a de novo bench trial in the Court of Common Pleas, which sentenced Haight to 30–90 days’ imprisonment.
- At the de novo trial Streit recanted portions of her prior statements, prompting Haight’s sufficiency challenge on appeal.
- The trial court credited the prior statements and physical evidence; the Superior Court reviewed whether, viewing the record in the light most favorable to the Commonwealth, the evidence was sufficient to sustain the harassment conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for harassment under 18 Pa.C.S. § 2709(a)(1) | Commonwealth: prior inconsistent statements, officer observations, and physical marks support conviction | Haight: victim recanted at trial, so evidence is insufficient to prove he struck her beyond a reasonable doubt | Affirmed: court held the record (including prior statements and physical evidence) was sufficient; fact‑finder may credit or discredit recantation |
Key Cases Cited
- Commonwealth v. Diamond, 83 A.3d 119 (discusses de novo review for sufficiency)
- Commonwealth v. Slocum, 86 A.3d 272 (standard for sufficiency review and deference to fact‑finder)
- Commonwealth v. Brown, 52 A.3d 1139 (prior inconsistent statements considered in sufficiency review and credibility assessment)
- Commonwealth v. Hanible, 836 A.2d 36 (recantation alone does not render evidence insufficient)