Com. v. Hallam, T.
701 WDA 2016
| Pa. Super. Ct. | Nov 23, 2016Background
- On Feb. 11, 2015, Victim gave Waylon Muniz and Travis Hallam a ride; destination changed and an altercation occurred in the car and outside.
- Victim testified Hallam struck him in the back of the head with a .22 Ruger revolver, sustaining lacerations and severe headache; police later recovered the gun nearby.
- Muniz reportedly choked Victim and took the car keys; Victim used a pocketknife to strike Hallam during the struggle; the two assailants fled when a bystander was called.
- Commonwealth charged Hallam with aggravated assault, simple assault, robbery, theft, and summary harassment; jury convicted him of aggravated and simple assault; bench convicted him of summary harassment; acquitted of remaining counts.
- Court sentenced Hallam to 24–48 months’ imprisonment; post-sentence motion for a new trial based on weight of the evidence was denied and Hallam appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether verdict was against the weight of the evidence | Commonwealth argued evidence (Victim testimony, recovered gun) supported convictions | Hallam argued the verdict shocked the conscience and weight favored acquittal | Court affirmed denial of new trial; jury credited Victim; verdict not contrary to evidence or against weight |
| Whether trial court erred by not striking Victim's unsolicited comment that he was "told not to call 911" | Commonwealth did not claim prejudice from the comment | Hallam argued the statement was prejudicial and should have been stricken | Court found no abuse of discretion or prejudice; comment elicited by defense and source was unidentified; no relief |
Key Cases Cited
- Commonwealth v. Champney, 574 Pa. 435, 832 A.2d 403 (2003) (standard for appellate review of weight-of-the-evidence claims)
- Commonwealth v. Rivera, 603 Pa. 340, 983 A.2d 1211 (2009) (trial court's denial of a weight-based new trial is highly deferential)
- Commonwealth v. Hyland, 875 A.2d 1175 (Pa. Super. 2005) (standard for reviewing admissibility of evidence and abuse of discretion)
- Commonwealth v. Robertson, 874 A.2d 1200 (Pa. Super. 2005) (erroneous evidentiary rulings require prejudice to warrant reversal)