Com. v. Rodgers, R., 1052 WDA 2023

Rico Rodgers was convicted in Beaver County, Pennsylvania, of third-degree murder, carrying a firearm without a license, and prohibited possession of a firearm following a fatal shooting on January 23, 2021.
Surveillance and eyewitness testimony confirmed Rodgers was involved in the incident where Karon Thomas was killed; Rodgers claimed the shooting was in self-defense.
The prosecution's case included video evidence, physical evidence from the scene, testimony of the driver (Nicole Nadzam), and an eyewitness (Susan Fennell), who testified Rodgers fired the first shot.
Rodgers testified he believed Thomas was about to shoot him and claimed Thomas fired first; however, the evidence showed Rodgers sought out the confrontation after a tense "look"-exchange.
Rodgers appealed the judgment of sentence, challenging the sufficiency and weight of the evidence supporting his murder conviction, specifically focusing on the self-defense claim.
The Superior Court reviewed the trial record, including testimony, forensic evidence, and procedural handling of post-sentence motions and appeal timing, and affirmed the conviction and sentence.

Issue	Rodgers' Argument	Commonwealth's Argument	Held
Sufficiency of the Evidence (Self-Defense)	Commonwealth failed to disprove self-defense beyond a reasonable doubt; Rodgers was not the aggressor and believed he faced imminent harm.	Rodgers was the initial aggressor; eyewitness testimony indicated Thomas was unarmed when Rodgers fired the first shot; Rodgers had a duty and opportunity to retreat.	Sufficient evidence supported conviction; jury reasonably found Rodgers was not justified in using deadly force.
Weight of the Evidence	Verdict contradicted the evidence and misapplied the law regarding self-defense; jury should have credited Rodgers' account.	Jury could credit Fennell’s testimony over Rodgers; conflicting testimony does not shock the conscience or require a new trial.	No abuse of discretion by trial court; verdict was not against weight of evidence.

Commonwealth v. Johnson, 236 A.3d 1141 (Pa. Super. 2020) (standard of review for sufficiency of the evidence challenges)
Commonwealth v. Franklin, 69 A.3d 719 (Pa. Super. 2013) (reviewing evidence in light most favorable to verdict winner)
Commonwealth v. Smith, 97 A.3d 782 (Pa. Super. 2014) (self-defense requires accused not to have provoked force and to retreat if possible)
Commonwealth v. Widmer, 744 A.2d 745 (Pa. 2000) (standards for weight of the evidence review)
Commonwealth v. Clay, 64 A.3d 1049 (Pa. 2013) (appellate review of weight claims focuses on discretion, not underlying facts)