Com. v. Hunter, D, 416 EDA 2015

On Jan. 13, 2014, Darrell Hunter assaulted the mother of his children, Nikkisha Whitfield, causing multiple injuries at her home after following her from a bus stop and a bar.
After the assault, Hunter attempted to re-enter Whitfield’s home through a barricaded backdoor while police were present and was arrested after a short chase.
While in custody and during the four months awaiting trial, Hunter repeatedly contacted Whitfield by phone and letter, making threats, asking her to drop charges, urging her not to testify, and offering money/other benefits if she did so.
Hunter was convicted after a bench trial of intimidation (18 Pa.C.S. § 4952), terroristic threats, burglary, and simple assault; the court sentenced him to 8–16 years’ imprisonment plus 10 years reporting probation.
Hunter appealed, arguing the evidence was insufficient to prove witness intimidation because his communications were at most inducements or generalized threats not intended to deter testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for witness intimidation under 18 Pa.C.S. § 4952	Commonwealth: evidence of assault plus subsequent threats, promises of money, and requests to drop charges show intent/knowledge to obstruct justice	Hunter: communications were generalized threats/inducements; no proof of intent to prevent testimony or actual intimidation	Court affirmed conviction: under Doughty, inducements paired with context (assault, threats, offers of benefit) can show sufficient indicia of intimidation under the totality of circumstances

Commonwealth v. Doughty, 126 A.3d 951 (Pa. 2015) (intimidation may be shown by totality of circumstances; pecuniary offers can contain indicia of intimidation even absent explicit threats)
Commonwealth v. Brachbill, 555 A.2d 82 (Pa. 1989) (discussed and limited by Doughty regarding whether pecuniary inducements alone suffice)