Com. v. Riggins, R.
37 EDA 2016
| Pa. Super. Ct. | Dec 1, 2017Background
- Raheim Riggins was convicted after a consolidated jury trial of multiple violent offenses arising from several incidents (including rape, aggravated assault, unlawful restraint, indecent assault, burglary, multiple robberies, conspiracy, and firearms offenses) and sentenced to an aggregate term of 36 to 72 years.
- Evidence included victim testimony, surveillance video/stills, photo-array identifications, forensic DNA and serology testing, recovered property tied to the defendants, co-defendant admissions, and inculpatory statements by Riggins.
- Riggins filed post-sentence motions in each of six consolidated cases and served six Rule 1925(b) concise statements (one per case); the trial court thought only one was served and initially treated other issues as waived.
- The Superior Court remanded for the trial court to address five specific sufficiency/weight/sentencing issues; the trial court nonetheless reasserted waiver as to some claims but provided alternative merits analysis.
- The Superior Court affirmed Riggins’s convictions and most sentencing rulings on the merits (adopting the trial court’s analyses), but sua sponte vacated the portion of the sentencing order designating Riggins a Sexually Violent Predator (SVP) under SORNA as legally defective and remanded for proper tiering and notice.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Riggins) | Held |
|---|---|---|---|
| Sufficiency of evidence (identification) | Sufficient circumstantial and direct evidence (victim IDs, video, recovered property, DNA, co-defendant admissions, Riggins’s statements) supports convictions. | Convictions insufficient where some victims could not identify Riggins; identification was inadequate for certain offenses. | Affirmed: viewing the record favorably to the Commonwealth, the evidence (including Riggins’s admissions, corroborating video/DNA/recovered property and witness testimony) was sufficient. |
| Weight of the evidence (specific incidents) | The jury was entitled to resolve credibility disputes; evidence was not so contrary or shocking to require a new trial. | Verdicts against the weight because key convictions rested largely on Riggins’s statements without independent corroboration (e.g., Wilson, J.B.K., Hawkins). | Affirmed: trial court properly exercised discretion; no extraordinary circumstances meriting a new trial. |
| Discretionary aspects of sentencing | Sentence (consecutive terms yielding 36–72 years) was reasonable given violent offenses, criminal history, and trial court consideration of factors. | Sentence excessive/illegal; trial court failed to follow guidelines or adequately explain consecutive terms; indecent assault sentence allegedly illegal. | Affirmed: sentencing court considered relevant factors, explained rationale, and did not impose an illegal sentence on indecent assault (no further penalty imposed). No abuse of discretion shown. |
| SVP designation under SORNA | Designation followed statutory procedure at sentencing under 42 Pa.C.S. §9799.24(e)(3). | Muniz and subsequent Superior Court authority require that factual findings increasing criminal punishment (SORNA registration tiers) be made beyond a reasonable doubt by the factfinder; the statutory standard (clear and convincing by court) is unconstitutional. | SVP designation vacated sua sponte: following Muniz and subsequent Superior Court rulings, the SVP finding/procedure as applied was legally defective; remanded for proper tier determination and notice consistent with controlling precedent. |
Key Cases Cited
- Muniz v. Commonwealth, 164 A.3d 1189 (Pa. 2017) (SORNA registration is punitive; Muniz requires criminal-procedural protections)
- Apprendi v. New Jersey, 530 U.S. 466 (2000) (facts increasing punishment must be found by jury beyond a reasonable doubt)
- Alleyne v. United States, 133 S. Ct. 2151 (2013) (holding that fact-finding that increases mandatory minimums must be submitted to jury and proved beyond reasonable doubt)
- Commonwealth v. Gribble, 703 A.2d 426 (Pa. 1997) (standard for appellate review of sentencing discretion)
- Commonwealth v. Patterson, 940 A.2d 493 (Pa. Super. Ct.) (discussing sufficiency review and appellate standards)