Com. v. Patterson, F., 1307 MDA 2015

On Jan. 11–12, 2014, homeless victim Robert Mohler was asleep in a Reading laundromat and was assaulted by multiple people; surveillance video captured the attack.
After an initial attack by Ferrer-Reyes and Allison, Appellant (Floyd Patterson) and Irich Colon returned and participated in a further beating; the victim sustained acute subdural hematomas and later died from his injuries.
Colon later identified Appellant from the videotape; Ferrer-Reyes was found in possession of the victim’s cell phone; police received an anonymous tip identifying Appellant.
Appellant was arrested and, after Miranda warnings, gave a recorded interview admitting to punching the victim and throwing a garbage can at him; Appellant made no trial objection to admission of the recording.
A jury convicted Appellant of aggravated assault, simple assault, recklessly endangering another person, and related conspiracy charges; he was sentenced to an aggregate 15 to 40 years’ imprisonment.
Appellant appealed, arguing (1) insufficiency of evidence to identify him as an assailant and (2) that the verdict was against the weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to identify Appellant	Commonwealth: Colon’s ID, surveillance video, and Appellant’s recorded confession suffice to prove identity beyond a reasonable doubt	Patterson: Identification was unreliable; recording "wrought with errors," authenticity/accuracy challenged	Affirmed — viewing evidence in Commonwealth’s favor, identity proved; confession admissible and unrebutted at trial
Weight of the evidence (identity)	Commonwealth: jury credibility determinations supported by video, confession, and Colon’s testimony	Patterson: verdict shocks conscience because identity evidence not credible	Affirmed — trial court did not abuse discretion; verdict not so contrary to evidence as to require new trial

Commonwealth v. Roberts, 133 A.3d 759 (Pa. Super. 2016) (standard for reviewing sufficiency of the evidence)
Commonwealth v. Brooks, 7 A.3d 852 (Pa. Super. 2010) (sufficiency review and circumstantial evidence can sustain conviction)
Commonwealth v. Leatherby, 116 A.3d 73 (Pa. Super. 2015) (standard for appellate review of weight-of-the-evidence claims)
Commonwealth v. Morales, 91 A.3d 80 (Pa. 2014) (new trial for verdicts that shock the conscience standard)
Commonwealth v. Sanchez, 36 A.3d 24 (Pa. 2011) (factfinder exclusively weighs credibility)
Commonwealth v. Page, 59 A.3d 1118 (Pa. Super. 2013) (credibility determinations lie with the factfinder)
Commonwealth v. Blackham, 909 A.2d 315 (Pa. Super. 2006) (appellate courts will not overturn factfinder’s credibility assessments)