Com. v. Redman, L., Com. v. Redman, L. No. 1363 WDA 2016

Lawrence Darnell Redman shot his girlfriend, Annamarie Henderson, four times on Sept. 24, 2011; he was convicted of attempted criminal homicide and two counts of aggravated assault and sentenced to 20–40 years.
At trial Redman testified he fired four "warning shots" toward the ground while retreating because he feared Henderson would use a knife; the shots nevertheless struck her.
Defense counsel decided, after consulting senior public defenders, not to request a jury instruction on self‑defense and instead relied on an accidental‑injury theory.
Redman filed a timely first PCRA petition claiming trial counsel was ineffective for failing to request a self‑defense instruction; an evidentiary hearing was held.
The PCRA court found counsel’s strategy reasonable and that Redman’s testimony admitted an unintentional shooting, which forecloses a self‑defense claim; the court denied relief.
The Superior Court affirmed, concluding no arguable merit to the ineffectiveness claim because an admission of an accidental shooting negates entitlement to a self‑defense instruction.

Issue	Appellant's Argument	Commonwealth's Argument	Held
Whether trial counsel was ineffective for not requesting a self‑defense jury instruction	Redman: testified he feared Henderson and meant to fire warning shots — counsel should have sought self‑defense instruction	Commonwealth: Redman testified to an unintentional shooting; self‑defense requires an admission the shooting was intentional; counsel reasonably chose accidental‑injury instruction	Court held counsel was not ineffective; no arguable merit because an accidental‑shooting admission precludes self‑defense

Commonwealth v. Philistin, 53 A.3d 1 (Pa. 2012) (holding an admission of an unintentional shooting forfeits a self‑defense claim)
Commonwealth v. Harris, 665 A.2d 1172 (Pa. 1995) (self‑defense requires admission that the shooting was intentional to protect oneself)
Commonwealth v. Hobson, 398 A.2d 1364 (Pa. 1979) (discussing necessity of intentionality for justification defenses)
Commonwealth v. Bracey, 795 A.2d 935 (Pa. 2001) (explaining imperfect self‑defense/imperfect justification principles)
Commonwealth v. Tilley, 595 A.2d 575 (Pa. 1991) (framework for unreasonable belief and imperfect self‑defense)
Commonwealth v. Busanet, 54 A.3d 34 (Pa. 2012) (standards for assessing PCRA claims)
Commonwealth v. Pierce, 527 A.2d 973 (Pa. 1987) (three‑prong test for ineffective assistance of counsel)
Commonwealth v. Dennis, 17 A.3d 297 (Pa. 2011) (PCRA standard of review and deference to court's credibility findings)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishing deficiency and prejudice standard for ineffective assistance)