Com. v. Reid, A., 3869 EDA 2016

On August 9, 2013 Antwine Reid argued with and then shot the victim multiple times, killing him; surveillance, eyewitnesses, and cartridge casings tied the event to the scene.
After a tip, officers detained Reid on September 20, 2013 and transported him to homicide; Detective Harkins recorded Reid’s biographical information (including a phone number) and later gave Miranda warnings; Reid left the station that morning.
Witnesses identified Reid as the shooter and described a revenge motive; cell‑phone records placed Reid near the crime scene at the time of the shooting and showed calls/texts with the victim shortly before the murder.
Police executed an arrest warrant on May 23, 2015 and obtained a search warrant for Reid’s phone records, which the Commonwealth introduced at trial.
Reid moved to suppress the phone records (arguing seizure without consent/Miranda failure) and later moved for a mistrial after a juror reported being approached by a man from the defense side; the trial court denied both motions.
A jury convicted Reid of first‑degree murder and related firearms offenses; the court imposed life without parole and concurrent 5–10 years; Reid appealed and the Superior Court affirmed.

Issue	Commonwealth's Argument	Reid's Argument	Held
Whether the trial court erred by refusing to suppress phone records as fruit of an illegal seizure/arrest	Waived at trial; alternatively, even if error, independent evidence (surveillance, eyewitness ID, phone data) made any error harmless	Police illegally seized Reid on the street and elicited biographical info (phone number) without Miranda or consent, so records are fruit of illegal seizure	Issue waived for failure to raise that theory below; alternatively harmless error if assumed errant
Whether the court should have granted a mistrial after a juror reported being approached by a spectator from the defense side	Court addressed the incident, excused the affected juror, individually questioned remaining jurors, sequestered jury at lunch, and removed persons matching description; no prejudice to fairness	Contact polluted the jury and created fear, warranting a mistrial	No abuse of discretion; trial court reasonably found no prejudice and took appropriate remedial steps

Commonwealth v. Brown, 52 A.3d 1139 (Pa. 2012) (jury may credit prior inconsistent statements over recantation)
Commonwealth v. Baez, 169 A.3d 35 (Pa. Super. 2017) (issues not raised below are waived on appeal)
Commonwealth v. Thur, 906 A.2d 552 (Pa. Super. 2006) (cannot raise new suppression theories on appeal)
Commonwealth v. Ragland, 991 A.2d 336 (Pa. Super. 2010) (mistrial standard; extreme remedy only when prejudice deprives defendant of fair trial)
Commonwealth v. Rush, 162 A.3d 530 (Pa. Super. 2017) (trial court’s juror‑impartiality and demeanor findings reviewed for abuse of discretion)
Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warning requirements)