Com. v. McFarland, M., Com. v. McFarland, M. No. 2200 EDA 2016

In 2014 Matthew McFarland attempted to purchase a handgun, answered “no” on forms asking whether he had been involuntarily committed, and certified the answers as true; the application was rejected after a background check revealed a 2003 involuntary commitment.
A jury convicted McFarland of making a materially false written statement in connection with a firearm purchase (18 Pa.C.S. §6111(g)(4)(ii)) and unsworn falsification to authorities (18 Pa.C.S. §4904(a)(1)).
McFarland’s central defense was that he suffered a traumatic brain injury in a 2001 accident and, based on neuropsychological testing and his own testimony, lacked memory of the 2003 involuntary commitment and therefore lacked intent to lie.
Commonwealth witnesses (including Detective Sgt. Patricia Doyle and family members) testified that McFarland was aware of or had reason to recall the commitment and that family/treatment contacts would have put him on notice.
The trial court denied McFarland’s post-trial motion for a new trial based on a weight-of-the-evidence claim and admitted limited testimony about (1) the underlying reason for the 2003 involuntary commitment (anger/aggression toward his brother) and (2) McFarland’s subsequent voluntary inpatient treatment, described in the record as treatment for “other issues.”
The Superior Court affirmed, holding the verdicts were not against the weight of the evidence and that the evidentiary rulings were proper exercises of discretion.

Issue	Appellant's Argument (McFarland)	Commonwealth / Trial Court Argument	Held
Weight of the evidence	McFarland argued his brain injury and expert neuropsychological testimony made the verdict shocking and that jury verdict should be reversed.	Jury credibility determinations favored Commonwealth; trial court found evidence of knowledge/intent credible.	Affirmed — no abuse of discretion; verdict not so contrary to evidence as to shock conscience.
Admission of reason for involuntary commitment	Testimony that commitment was for aggression toward his brother was prejudicial and irrelevant to whether McFarland remembered the commitment.	Testimony was limited, relevant to whether family/treatment discussions would have put McFarland on notice; probative value outweighed prejudice.	Affirmed — admission was limited, sanitized, and not an abuse of discretion under Pa.R.E. 403.
Admission of voluntary inpatient treatment (Malvern Institute) described as “other issues”	Reference to inpatient treatment (a known drug/alcohol facility) was prejudicial under Pa.R.E. 404(b) and could mislead jury about character or addiction.	Reference was sanitized as treatment for “other issues” to avoid prejudice; relevant to showing McFarland would have discussed hospitalization in counseling.	Affirmed — limiting wording reduced prejudice; evidence admissible for non-character purpose and not an abuse of discretion.

Commonwealth v. Lyons, 79 A.3d 1053 (Pa. 2013) (standard for weight-of-the-evidence claim)
Commonwealth v. Clay, 64 A.3d 1049 (Pa. 2013) (limits on discretionary review and abuse of discretion standard)
Commonwealth v. Mucci, 143 A.3d 399 (Pa. Super. 2016) (weight claim requires evidence so tenuous that verdict shocks conscience)
Commonwealth v. Sanchez, 36 A.3d 24 (Pa. 2011) (appellate court will not reweigh credibility determinations)
Commonwealth v. Bryant, 67 A.3d 716 (Pa. 2013) (appellate review of evidentiary rulings and abuse-of-discretion standard)
Commonwealth v. Christine, 125 A.3d 394 (Pa. 2015) (Pa.R.E. 401–403 relevance and balancing principles)