Com. v. Samuels, A.
1758 MDA 2016
| Pa. Super. Ct. | Nov 9, 2017Background
- Anthony Darnell Samuels was convicted after a non-jury trial of terroristic threats for repeatedly demanding money from his ex-girlfriend, Larita Brown, and threatening to kill her.
- Events occurred Feb. 16, 2016: confrontation at a train station, continued harassment on a public bus where Brown paid $20 while shaken, and subsequent threatening phone calls.
- Brown had a prior PFA against Samuels and testified she feared for her life; police matched call records to Samuels.
- Trial court found a settled purpose to terrorize given repeated incidents over hours and prior abusive history.
- Court sentenced Samuels to 24–60 months’ incarceration plus fines; post-sentence motion denied and appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to prove terroristic threats | Commonwealth: evidence showed threats to commit violence and intent to terrorize based on conduct that caused fear | Samuels: statements were heat-of-the-moment/transitory anger, lacked intent to terrorize | Affirmed — evidence sufficient: repeated threats over time, victim’s fear, prior abuse support intent to terrorize |
| Discretionary aspects of sentence (excessiveness) | Commonwealth/Trial court: sentence considered public safety, aggravating history, need for protection and treatment | Samuels: sentence excessive given age, mental health, addiction, rehabilitative needs | Affirmed — no manifest abuse of discretion; court considered PSI, history, and imposed aggravated-range term with mental health evaluation ordered |
Key Cases Cited
- Commonwealth v. Widmer, 744 A.2d 745 (Pa. 2000) (standard for reviewing sufficiency of the evidence)
- Commonwealth v. Beasley, 138 A.3d 39 (Pa. Super. 2016) (elements and intent standard for terroristic threats)
- Commonwealth v. Reynolds, 835 A.2d 720 (Pa. Super. 2003) (terroristic threats protects against psychological distress and invasion of personal security)
- Commonwealth v. Gould, 912 A.2d 869 (Pa. Super. 2006) (standard and preservation for discretionary-sentencing review)
- Commonwealth v. Kelly, 33 A.3d 638 (Pa. Super. 2011) (what constitutes a substantial question for appellate review of sentence)
- Commonwealth v. Anneski, 525 A.2d 373 (Pa. Super. 1987) (distinguishing spur-of-the-moment threats from settled intent to terrorize)