Com. v. Reavis, J., 328 EDA 2014

Victim Babatunde Olabode owned a duplex; appellant James Reavis lived upstairs while Olabode used the ground-floor unit to store tools.
On July 6, 2012, Olabode observed Reavis and two others enter the ground-floor unit, remove tools, and load them into a car; Olabode confronted Reavis.
Reavis reportedly lifted his shirt to display a semiautomatic pistol and said, “Nigger, if you come here I’ll blow your head off.”
Reavis was arrested and charged with multiple offenses; a jury convicted him only of terroristic threats under 18 Pa.C.S. § 2706(a)(1).
He was initially sentenced to 2½ to 5 years, which was vacated on post-sentence motion and replaced with five years probation.
Reavis appealed contending insufficient evidence supported the terroristic-threats conviction; the Superior Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether sufficient evidence supported conviction for terroristic threats	Commonwealth: Olabode’s testimony that Reavis displayed a pistol and threatened to "blow [his] head off" proved a threat to commit violence made with intent to terrorize	Reavis: Evidence was insufficient to prove the elements of terroristic threats beyond a reasonable doubt	Affirmed — viewing the evidence in the light most favorable to the Commonwealth, the jury could find all elements proven beyond a reasonable doubt

Anders v. California, 386 U.S. 738 (U.S. 1967) (standards for counsel seeking to withdraw on appeal)
Santiago v. Commonwealth, 978 A.2d 349 (Pa. 2009) (procedural requirements for Anders-type brief in Pennsylvania)
Lehman v. Commonwealth, 820 A.2d 766 (Pa. Super. 2003) (standard of review for sufficiency of the evidence)
Hudgens v. Commonwealth, 582 A.2d 1352 (Pa. Super. 1990) (threat need not specify criminal act; context may supply the intended crime)
Reynolds v. Commonwealth, 835 A.2d 720 (Pa. Super. 2003) (elements and intent analysis for terroristic threats statute)