Com. v. Reid, J., Jr.
Com. v. Reid, J., Jr. No. 1194 MDA 2016
| Pa. Super. Ct. | Jul 27, 2017Background
- Jeffrey Allen Reid, Jr. participated in a series of attempted robberies and, when those failed, arranged to have Dashaun (Deshaun) Davis brought to his residence to rob him.
- During the encounter, co-defendant NaQuan Coakley shot Davis after Davis reached for Coakley’s gun; Reid reportedly told Coakley to “finish him” or “off him.”
- After the shooting, Reid asked others to help dispose of the body; they refused and the group dispersed when police sirens were heard.
- In custody, Reid asked cellmate Andrew Horn to write a letter to Reid’s lawyer falsely stating Coakley admitted the shooting; Horn did not send the letter and instead testified for the prosecution. Malik Williams (Coakley’s brother) also testified against Reid.
- A jury convicted Reid of first‑ and second‑degree murder and related robbery charges; the trial court sentenced him to life without parole for first‑degree murder plus consecutive terms on other counts. Reid appealed, raising sufficiency (first and second degree) and a Brady claim about undisclosed phone billing records.
Issues
| Issue | Plaintiff's Argument (Reid) | Defendant's Argument (Commonwealth) | Held |
|---|---|---|---|
| Sufficiency of evidence for first‑degree murder | Evidence insufficient to prove Reid had specific intent to kill or was an accomplice; chief trial witness (Horn) not credible | Evidence (including Horn and Williams) showed Reid conspired to rob Davis and ordered Coakley to kill him; intent can be proven circumstantially | Reid’s sufficiency claim was treated as a credibility/weight challenge (waived); on the merits evidence sufficed to support first‑degree conviction |
| Sufficiency of evidence for second‑degree murder | Record lacks credible evidence tying Reid to felony murder as accomplice | Same evidence supports felony‑murder theory (killing in course of robbery) | Claim failed for same reasons as first‑degree: credibility issue (weight) waived; evidence sufficient on the merits |
| Brady violation for undisclosed phone billing records | Commonwealth withheld billing records for victim’s phone; their absence undermines Horn’s testimony that Reid called Davis to set up the robbery | Records contained no message content; Reid’s counsel conceded uncertainty as to favorability; absence of a record for receipt of a text is speculative and would not undermine verdict | No Brady violation: defendant failed to show evidence was favorable, suppressed, or material to the outcome; no prejudice shown |
Key Cases Cited
- Palo v. Commonwealth, 24 A.3d 1050 (Pa. Super. 2011) (credibility challenges go to weight, not sufficiency)
- Dougherty v. Commonwealth, 860 A.2d 31 (Pa. 2004) (weight of evidence is jury province)
- Small v. Commonwealth, 741 A.2d 666 (Pa. 1999) (credibility‑as‑sufficiency arguments treated as weight claims)
- Perez v. Commonwealth, 93 A.3d 829 (Pa. 2014) (circumstantial evidence may establish intent for first‑degree murder)
- Chambers v. Commonwealth, 980 A.2d 35 (Pa. 2009) (specific intent to kill can form in an instant)
- Weiss v. Commonwealth, 986 A.2d 808 (Pa. 2009) (Brady materiality standard; withheld impeachment evidence must undermine confidence in verdict for relief)