Com. v. Newton, I.
2024 Pa. Super. 127
| Pa. Super. Ct. | 2024Background
- Isaiah Scott Newton (Appellee) was involved in an altercation where he retrieved a kitchen knife, stabbed the victim in the left bicep, and the victim later died from a severed brachial artery.
- The Commonwealth charged Newton with first-degree murder, alleging specific intent to kill based on the facts of the stabbing.
- The trial court dismissed the first-degree murder charge, finding insufficient evidence of specific intent to kill, noting the weapon was not used on a vital organ.
- The Commonwealth appealed, arguing enough circumstances existed to infer intent to kill, and the deadly weapon presumption should apply.
- The Superior Court Majority reversed the trial court, but this opinion is a dissent arguing there was no sufficient evidence of specific intent for first-degree murder.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for specific intent | Newton's actions show intent to kill (retrieved knife, etc.) | No evidence of specific intent; wound was to the arm, not vital. | Dissent: Insufficient intent |
| Deadly weapon presumption on a non-vital site | Presumption applies since arm injury can be fatal | Arm is not a vital organ for presumption purposes | Dissent: Presumption not met |
| Weight of pre-stabbing events and knife retrieval | Events before stabbing show planning and intent | Unclear altercation details; no clear animus or fatal targeting | Dissent: Not enough evidence |
| Post-stabbing conduct as evidence of intent | Cleaning knife shows guilty intent for murder | Only shows consciousness of guilt, not specific intent to kill | Dissent: Insufficient for intent |
Key Cases Cited
- Commonwealth v. Styler, 600 A.2d 1300 (Pa. Super. 1991) (Trial court shouldn't quash first-degree murder at prelim under some circumstances, e.g. stabbing in the chest.)
- Commonwealth v. Pursell, 495 A.2d 183 (Pa. 1985) (Premeditation may be inferred where weapon is procured and used in fatal attack; distinguished on facts.)
- Commonwealth v. Ballard, 80 A.3d 380 (Pa. 2013) (Multiple stabbing wounds with specific weapon establish specific intent.)
- Commonwealth v. Randolph, 873 A.2d 1277 (Pa. 2005) (First-degree murder requires evidence of willful, deliberate, and premeditated killing.)
- Commonwealth v. Wesley, 753 A.2d 204 (Pa. 2000) (Specific intent distinguishes first-degree from other murder degrees.)
- Commonwealth v. Predmore, 199 A.3d 925 (Pa. Super. 2018) (Insufficient evidence of specific intent means charge should not go to jury.)