Com. v. Hughes, J., 2071 EDA 2016

On Jan 9, 2012, appellant Jamie L. Hughes babysat his fiancée’s 21‑month‑old daughter, A.J., from early morning until about 8:00 p.m.; A.J. was fine when the mother called at ~7:45 p.m., and shortly thereafter Hughes reported the child was badly hurt.
A.J. suffered multiple severe injuries (four rib fractures, subdural hemorrhage, retinal hemorrhages, swollen pancreas, torn liver, brain swelling/ischemia) and required more than a week in intensive care; hospital staff concluded the injuries indicated abuse and notified authorities.
Police investigation led to an arrest warrant in July 2012; Hughes surrendered, posted bail, later missed court dates, was rearrested in April 2015, and tried by the bench on Nov 23, 2015.
The trial court found Hughes guilty of aggravated assault, endangering the welfare of a child, simple assault, and recklessly endangering another person; he was sentenced to 4½ to 9 years’ incarceration plus five years’ probation.
Hughes filed post‑sentence motions arguing sufficiency and weight of the evidence; the Superior Court reviewed those claims and affirmed the judgment on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to sustain convictions	Commonwealth: medical and investigative evidence establishes A.J. suffered severe, inflicted injuries while in Hughes’ sole custody, supporting aggravated assault and related counts	Hughes: injuries could be accidental (a short fall); he was cooperative and called for help, creating reasonable doubt	Held: Evidence sufficient. Medical expert testified injuries were inflicted and acute; circumstantial evidence linked Hughes to the abuse and supported the convictions.
Weight of the evidence	Commonwealth: trial court properly credited medical testimony and inferences of guilt from the evidence	Hughes: his consistent testimony, prompt aid, and cooperation indicate innocence; verdict shocks justice	Held: No abuse of discretion. Trial court reasonably discredited Hughes and credited expert testimony; verdict did not shock the conscience.

Commonwealth v. Widmer, 744 A.2d 745 (Pa. 2000) (standard for sufficiency and weight review)
Commonwealth v. Stokes, 78 A.3d 644 (Pa. Super. 2013) (sufficiency review framing)
Commonwealth v. Smith, 956 A.2d 1029 (Pa. Super. 2008) (size/strength disparity supports mens rea inference in child‑abuse aggravated assault)
Commonwealth v. Brown, 605 A.2d 429 (Pa. Super. 1992) (simple assault is lesser included offense of aggravated assault)
Commonwealth v. Diggs, 949 A.2d 873 (Pa. 2008) (weight‑of‑evidence reversal standard — shocks sense of justice)
Commonwealth v. Houser, 18 A.3d 1128 (Pa. 2011) (appellate review of weight claims limited to abuse of discretion)
Commonwealth v. Estepp, 17 A.3d 939 (Pa. Super. 2011) (factfinder may accept or reject witness testimony)