Com. v. Nieto-Vides, F., Com. v. Nieto-Vides, F. No. 1797 MDA 2016

On Dec. 23, 2014, Nieto-Vides attempted to buy $11 worth of goods at Redner’s with a $100 bill; the store’s counterfeit-detection scanners rejected the bill.
Store manager Jason Krick ran the bill through two scanners repeatedly, observed abnormal color/watermark, and compared it to another rejected $100 from earlier that day.
Trooper Huffstutler found a nearly identical $100 in Appellant’s purse and, after a vehicle search, discovered a backpack with multiple $100 bills (some sharing serial numbers), $1,827 in smaller bills, and many shopping bags.
Appellant was charged with forgery, attempted forgery, conspiracy to commit forgery, attempted theft by deception, and conspiracy to commit theft by deception; jury convicted her of one forgery, attempted forgery, and related conspiracy counts but acquitted on theft by deception and other forgery counts.
Trial court denied post-sentence motions; appellant appealed arguing insufficiency (bill counterfeit, knowledge, conspiracy) and that the verdict was against the weight of the evidence.

Issue	Appellant's Argument	Commonwealth/Trial Court Argument	Held
Whether evidence proved the $100 bill was counterfeit	Evidence insufficient without expert testimony about scanners and serial-number significance	Lay testimony (scanner rejections, bill appearance, circumstantial context) sufficed	Affirmed — circumstantial evidence and lay observations sufficient to support counterfeit finding
Whether Appellant knew the bill was counterfeit	Appellant’s providing contact info and waiting for police showed lack of knowledge	Attempt to leave store, possession of other identical bills, large cash stash imply knowledge	Affirmed — jury could infer knowledge from conduct and surrounding facts
Whether Appellant conspired with two men to pass counterfeit bills	No evidence she was traveling with the men or agreed with them	Trooper’s vehicle search, photo IDs showing same out‑of‑state residence, and proximity supported inference they traveled together	Affirmed — record supported conspiracy inference
Whether the verdict was against the weight of the evidence	Verdict shocks justice; jury should have credited alternative inferences	Trial court exercised discretion; facts did not overwhelmingly favor innocence	Affirmed — no palpable abuse of discretion in denying new-trial motion

Mucci v. Commonwealth, 143 A.3d 399 (Pa. Super. 2016) (standard for sufficiency review and allowance of circumstantial evidence)
Brooks v. Commonwealth, 7 A.3d 852 (Pa. Super. 2010) (credibility and weight considerations)
Kuykendall v. Commonwealth, 2 A.3d 559 (Pa. Super. 2010) (appeal challenging post‑sentence motion procedure)
Rayner v. Commonwealth, 153 A.3d 1049 (Pa. Super. 2016) (weight-of-the-evidence motion concedes sufficiency)
Widmer v. Commonwealth, 744 A.2d 745 (Pa. 2000) (standard for weight-of-the-evidence review)
Cash v. Commonwealth, 137 A.3d 1262 (Pa. 2016) (trial court discretion on new‑trial weight claims)
Colon‑Plaza v. Commonwealth, 136 A.3d 521 (Pa. Super. 2016) (deference to trial court on weight rulings)
Clay v. Commonwealth, 64 A.3d 1049 (Pa. 2013) (trial court weight determination is hard to overturn)
Lyons v. Commonwealth, 833 A.2d 245 (Pa. Super. 2003) (definition of verdict contrary to weight of the evidence)