Com. v. Holloway, K., Com. v. Holloway, K. No. 3758 EDA 2015

Victim Antoine Wilkinson died from a single stab wound to the lower anterior chest that lacerated the left main pulmonary artery.
Appellee Kenyatta Holloway lived with Wilkinson; Holloway’s 10‑year‑old brother (J.F.) heard a heated argument, was sent outside, then called back in and found Wilkinson on the floor and a knife nearby; the knife was gone before police arrived.
Holloway instructed J.F. to clean up broken glass and later told Detective Burke Wilkinson returned home already stabbed and blamed a third person; that story proved false.
Commonwealth charged Holloway with murder generally and possession of an instrument of crime; at the preliminary hearing the municipal court barred first‑degree murder for lack of evidence of specific intent.
Commonwealth sought to refile first‑degree murder; the trial court denied refiling. The Commonwealth appealed to the Superior Court, which reversed and remanded, finding a prima facie case for first‑degree murder.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Commonwealth presented sufficient evidence at the preliminary stage to establish a prima facie case of first‑degree murder (i.e., that Holloway acted with malice and specific intent to kill)	Evidence that Holloway stabbed Wilkinson in the chest (a vital area), hid the weapon, cleaned the scene, and lied to police supports an inference of specific intent to kill and consciousness of guilt	The stabbing occurred during a heated mutual affray; a single stab alone (and post‑event concealment) is insufficient to prove specific intent—only malice, not premeditation	Reversed: viewing evidence in Commonwealth’s favor, the use of a deadly weapon on a vital part plus concealment and deception sufficed to establish a prima facie case of first‑degree murder for preliminary‑hearing purposes

Commonwealth v. Claffey, 80 A.3d 780 (Pa. Super. 2013) (prima facie requirement at preliminary hearing)
Commonwealth v. Dantzler, 135 A.3d 1109 (Pa. Super. 2016) (plenary review of legal sufficiency at preliminary hearing)
Commonwealth v. Landis, 48 A.3d 432 (Pa. Super. 2012) (view evidence in light most favorable to Commonwealth; consider reasonable inferences)
Commonwealth v. Woodard, 129 A.3d 480 (Pa. 2015) (elements of first‑degree murder require specific intent to kill)
Commonwealth v. Mattison, 82 A.3d 386 (Pa. 2013) (specific intent can be proven circumstantially, such as using a deadly weapon on a vital part)
Commonwealth v. Hitcho, 123 A.3d 731 (Pa. 2015) (premeditation can be formed in a very brief period)