Com. v. Knight, T., 1428 WDA 2016

Early May 16, 2015, Knight was hiding in a small bedroom in Jefferson Hills after a consensual encounter with Crystal McIver; Darius Williams (McIver’s boyfriend) unexpectedly returned home armed with a folding knife.
Williams entered the bedroom, turned on the light, and was heard to exclaim; three gunshots followed and Williams left the bedroom, later dying of three gunshot wounds.
Knight fled the scene in boxer shorts; his clothing with ID was later recovered at the residence; the firearm was not recovered.
Knight was tried non-jury, convicted of voluntary manslaughter and persons not to possess a firearm, acquitted of tampering with evidence, and sentenced to 10–20 years (manslaughter) concurrent with 5–10 years (firearm).
Knight appealed, arguing the Commonwealth failed to disprove his self‑defense claim (sufficiency) and that the verdict was against the weight of the evidence; the Superior Court reviewed legal sufficiency regarding self‑defense and whether the Commonwealth proved excess force.

Issue	Plaintiff's Argument (Commonwealth)	Defendant's Argument (Knight)	Held
Whether evidence was sufficient to disprove Knight’s claim of justifiable self‑defense for the killing	Commonwealth argued Knight used excessive, unjustified deadly force and thus self‑defense was negated	Knight argued he was not the initial provocateur, had no safe avenue of retreat (knife blocked the only exit), and reasonably believed deadly force was necessary	Court held Commonwealth failed to disprove justifiable self‑defense beyond a reasonable doubt; vacated manslaughter conviction and reversed sentence
Whether conviction was against the weight of the evidence (trial court’s reliance on facts and assessment of self‑defense)	Commonwealth relied on trial court credibility findings that Knight used excessive force (victim backing out, shots to the back)	Knight argued trial court ignored undisputed evidence and misapplied self‑defense law	Court did not reach weight claim after resolving sufficiency in Knight’s favor (issue rendered moot)

Commonwealth v. Fitzpatrick, 159 A.3d 562 (Pa. Super. 2017) (standards for sufficiency review)
Commonwealth v. Smith, 97 A.3d 782 (Pa. Super. 2014) (Commonwealth must disprove self‑defense beyond a reasonable doubt)
Commonwealth v. Harris, 665 A.2d 1172 (Pa. 1995) (elements for justified use of deadly force)
Commonwealth v. Mayfield, 585 A.2d 1069 (Pa. Super. 1991) (brandishing a knife can constitute deadly force)
Commonwealth v. Jones, 332 A.2d 464 (Pa. Super. 1974) (supporting authority that knife use may be deadly force)