Com. v. Martin, C.
230 EDA 2017
| Pa. Super. Ct. | Dec 11, 2017Background
- On December 22, 2014, Nichelson Raymond was shot and killed during an attempted robbery arranged as a marijuana purchase; Monserrat Rosas (a minor) served as the buyer and eyewitness.
- Charles Daniel Martin, III (Appellant), Lael Alleyne, and Gary Bridges, Jr. were alleged co-conspirators; Alleyne was identified as the shooter.
- Rosas testified she saw Appellant in the passenger seat of a Jaguar, wearing a navy pea coat, draw a gun near the SUV holding Raymond and Richard Piscoya; she heard multiple shots.
- Cell phone records and call patterns linked Appellant with Alleyne and Bridges around the times of planning and the shooting; surveillance and social-media/phone records corroborated movements. A pea coat matching Rosas’s description was found in Appellant’s friend’s residence after his arrest.
- Appellant was convicted after a joint trial with Alleyne (who was convicted of first-degree murder); Appellant received an aggregate 28–56 year sentence. He did not file a post-sentence motion and appealed.
- On appeal, Appellant challenged (1) sufficiency of the evidence and (2) weight of the evidence (attacking Rosas’s credibility and lack of forensic corroboration). The Superior Court affirmed.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Martin) | Held |
|---|---|---|---|
| Sufficiency of the evidence | Evidence (eyewitness testimony, phone records, surveillance, coat) sufficed to prove conspiracy, robbery, and murder participation | Evidence insufficient: no DNA/forensic linkage, unreliable eyewitness, cell-tower inferences weak; Commonwealth failed to prove elements | Waived for lack of specificity in Rule 1925(b); alternatively, evidence (including Rosas’s eyewitness testimony and corroborating records) was sufficient |
| Weight of the evidence | Credibility and weight are for the jury; corroborating evidence supports verdict | Verdict against weight: Rosas biased/unreliable; Commonwealth failed to corroborate her testimony | Waived for failure to file a post-sentence motion; not preserved for appeal |
Key Cases Cited
- Commonwealth v. Lewis, 45 A.3d 405 (Pa. Super. 2012) (post-sentence motion required to preserve weight claim)
- Commonwealth v. Gonzalez, 109 A.3d 711 (Pa. Super. 2015) (sufficiency standard and circumstantial evidence can suffice)
- Commonwealth v. Duncan, 373 A.2d 1051 (Pa. 1977) (single eyewitness testimony can support a conviction)
- Commonwealth v. Mikell, 729 A.2d 566 (Pa. Super. 1999) (conviction may rest on uncorroborated accomplice testimony)
- Commonwealth v. Brown, 52 A.3d 1139 (Pa. 2012) (credibility and reliability questions are for the fact-finder; only in rare cases will sufficiency review overturn verdict for unreliable evidence)
- Commonwealth v. Roche, 153 A.3d 1063 (Pa. Super. 2017) (Rule 1925(b) specificity requirement for sufficiency claims)
- Commonwealth v. Stiles, 143 A.3d 968 (Pa. Super. 2016) (importance of specifying elements challenged where multiple crimes convicted)
- Commonwealth v. Gibbs, 981 A.2d 274 (Pa. Super. 2009) (waiver of sufficiency claim where appellant fails to specify elements and cite authority)