Com. v. White, D.
Com. v. White, D. No. 2418 EDA 2015
| Pa. Super. Ct. | Feb 21, 2017Background
- Dontae D. White was convicted after a bench trial of multiple offenses including possession with intent to deliver, simple possession, possession of a firearm by a prohibited person, carrying firearms offenses, and conspiracy.
- The convictions arose from evidence seized at his arrest (details of the seizure are in the trial court record but not restated in the Superior Court memorandum).
- White appealed, filing a Pa.R.A.P. 1925(b) concise statement that challenged denial of his suppression motion and sufficiency of the evidence.
- The statement, however, lacked specificity required by Pa.R.A.P. 1925(b)(4)(ii); it failed to identify particular errors or the elements allegedly unsupported by the Commonwealth’s evidence.
- The trial court found the 1925(b) statement too vague to permit meaningful review and deemed the issues waived; the Superior Court agreed and affirmed the judgment of sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in denying White's pretrial motion to suppress physical evidence | Commonwealth: suppression denial proper; evidence admissible | White: suppression should have been granted (statement in 1925(b) asserted error but gave no specifics) | Waived for appellate review due to non‑specific 1925(b) statement; no review on merits |
| Whether the Commonwealth produced sufficient evidence to sustain convictions (PWID, conspiracy, firearms offenses) | Commonwealth: presented sufficient evidence to prove elements beyond a reasonable doubt | White: evidence was insufficient (1925(b) referenced insufficiency generally but did not specify which elements) | Waived for appellate review because Rule 1925(b) did not specify which elements were allegedly lacking; judgment affirmed |
Key Cases Cited
- Commonwealth v. Reeves, 907 A.2d 1 (Pa. Super. 2006) (Rule 1925(b) specificity requirement explained)
- Lineberger v. Wyeth, 894 A.2d 141 (Pa. Super. 2006) (related authority on Rule 1925(b) specificity)
- Commonwealth v. Hansley, 24 A.3d 410 (Pa. Super. 2011) (concise statement must identify errors for trial court to address)
- Commonwealth v. Dowling, 778 A.2d 683 (Pa. Super. 2001) (courts should not be forced to guess appellant's issues)
- Commonwealth v. Garland, 63 A.3d 339 (Pa. Super. 2013) (sufficiency challenges require Rule 1925(b) specificity as to elements)
- Commonwealth v. Gibbs, 981 A.2d 274 (Pa. Super. 2009) (Rule 1925(b) specificity applied where multiple offenses with distinct elements are charged)
- Commonwealth v. Williams, 959 A.2d 1252 (Pa. Super. 2008) (discusses preservation and specificity requirements under Rule 1925(b))