Com. v. Jennings, K., Com. v. Jennings, K. No. 3790 EDA 2016

On June 21, 2013, police responded to gunshots; officers observed Jennings run, stop behind bushes, then walk away. A stop recovered $154 and a marijuana blunt on Jennings; a search of the bushes recovered $317, three small baggies of marijuana, and a .32 Walther handgun with an obliterated serial number. Jennings was arrested.
At the station Jennings made spontaneous statements to Detective Miller, later asked to speak and indicated interest in working as a confidential informant; Miller read Miranda warnings line-by-line, Jennings executed a written waiver, and in a recorded interview admitted ownership/possession of the gun, drugs, and money.
Commonwealth charged Jennings with multiple firearm and drug-related offenses; trial resulted in jury convictions on several counts and a bench conviction on a persons-not-to-possess-firearms count; aggregate sentence 4½ to 10 years.
Jennings filed a suppression motion claiming his Miranda waiver and confession were coerced (Detective Miller allegedly promised he would get off “scot-free”); he also claimed a necessity defense at trial (that he only took the gun for protection). Trial court denied suppression and rejected weight challenge; post-sentence motion denied.
Counsel sought to withdraw under Anders/Santiago; the Superior Court independently reviewed the record, found the appeal frivolous, affirmed the judgment, and granted counsel’s Anders petition to withdraw.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jennings’s Miranda waiver was involuntary/coerced	Detective Miller coerced a waiver by promising he’d get off “scot-free” if he claimed possession was for protection; waiver and confession were fabricated and involuntary	Miller read Miranda rights line-by-line, Jennings acknowledged understanding and signed a written waiver; no coercive inducement shown	Waiver was knowing/voluntary; suppression properly denied
Whether verdict was against the weight of the evidence given a necessity defense	Jennings contends he took the gun from a shooter for protection and did not own it; jury should have accepted necessity and acquitted	Commonwealth presented testimony, recovered gun and items at location, and a recorded confession admitting ownership; credibility for jury to resolve	Trial court did not abuse discretion; weight claim denied

Miranda v. Arizona, 384 U.S. 436 (custodial interrogation requires warnings)
Anders v. California, 386 U.S. 738 (procedures for counsel seeking to withdraw on appeal)
Commonwealth v. Santiago, 602 Pa. 159 (Pa. 2009) (Anders-briefing requirements clarified for appointed counsel)
Commonwealth v. Champney, 574 Pa. 435 (Pa. 2003) (standard for appellate review of weight-of-the-evidence claims)
Commonwealth v. Widmer, 560 Pa. 308 (Pa. 2000) (trial court’s role and limits when deciding weight claims)