Com. v. Whitefield, A.
Com. v. Whitefield, A. No. 2103 EDA 2016
| Pa. Super. Ct. | Jul 31, 2017Background
- Alfred Whitefield was convicted in a waiver trial of two counts of first-degree murder and several firearm- and related offenses for a 2013 double homicide in Philadelphia; the court imposed consecutive life without parole sentences for the murders.
- Victim Carmen Medina and Thomas Gorman were shot after an interaction at a drug corner; eyewitness Yvette Davila testified that Whitefield turned and fired at the victims.
- A jailhouse informant (Angel Torres) testified that Whitefield confessed to killing Medina and Gorman over a $500 rent dispute for the drug-selling corner.
- Additional evidence: Whitefield’s girlfriend testified he told her to cut service to his phone; police triangulated his phone to the scene at the time of the murders.
- Post-sentence motion was denied by operation of law; Whitefield filed a timely appeal raising sufficiency and weight-of-the-evidence claims, but his Rule 1925(b) statement failed to specify sufficiency elements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Commonwealth contends the evidence (eyewitness ID, confession, phone location) supports convictions | Whitefield argued verdict was against sufficiency (generally asserted in Rule 1925(b)) | Court found sufficiency issue not preserved because 1925(b) did not identify specific elements; only weight claim reviewed |
| Weight of the evidence | Commonwealth argues credibility determinations were for the trial court and evidence supports verdict | Whitefield asked appellate court to reweigh credibility and attack witnesses (eyewitness, jailhouse informant, girlfriend) | Court declined to reweigh; affirmed trial court’s denial of new-trial motion — verdict did not shock the conscience |
Key Cases Cited
- Commonwealth v. Gibbs, 981 A.2d 274 (Pa. Super. 2009) (Rule 1925(b) must specify elements challenged for sufficiency claims)
- Commonwealth v. Wilson, 825 A.2d 710 (Pa. Super. 2003) (credibility attacks generally challenge weight, not sufficiency)
- Commonwealth v. Gaskins, 692 A.2d 224 (Pa. Super. 1997) (fact-finder determines credibility; credibility challenges go to weight)
- Commonwealth v. Clay, 64 A.3d 1049 (Pa. 2013) (standard of review and discretion for weight-of-the-evidence claims)
- Commonwealth v. Talbert, 129 A.3d 536 (Pa. Super. 2013) (verdict will be overturned for weight only if evidence is so tenuous that it shocks the conscience)