Com. v. Wiggins, D., 1754 EDA 2024

Deandre Wiggins, at age 16, committed a series of violent crimes in Philadelphia in August 2022, including two third-degree murders, five aggravated assaults with a deadly weapon, and a carjacking.
His offenses included two deadly shootings: one at a Popeye’s parking lot resulting in one death and two injuries, and another at a residential porch killing one and injuring three others, followed by an armed carjacking the next day.
Wiggins pled guilty to an array of charges across three consolidated cases, including murder, conspiracy, aggravated assault, and firearms offenses.
At sentencing, the trial court considered Wiggins’ extensive juvenile record, his young age, difficult personal history, prior failed rehabilitative efforts, and the impact on the victims and community.
The court imposed an aggregate sentence of 40 to 80 years’ incarceration, stating that anything less would denigrate the seriousness of the crimes.
Wiggins challenged his sentence, arguing the court failed to properly weigh mitigating factors, including his youth, acceptance of responsibility, remorse, and rehabilitative potential.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by imposing a 40-80 year sentence without adequately considering mitigating factors (youth, remorse, rehabilitative potential)	Wiggins: Trial court focused only on seriousness of offense and impact on victims, not mitigation.	Commonwealth: Sentence appropriate due to crime severity and danger posed; all factors considered.	No abuse of discretion; sentence affirmed.

Commonwealth v. Sierra, 752 A.2d 910 (Pa. Super. 2000) (sets general test for appellate review of sentencing discretionary issues)
Commonwealth v. Griffin, 65 A.3d 932 (Pa. Super. 2013) (defining substantial question for sentencing appeals)
Commonwealth v. Moury, 992 A.2d 162 (Pa. Super. 2010) (substantial question standard regarding mitigation/rehabilitation arguments on appeal)
Commonwealth v. Shugars, 895 A.2d 1270 (Pa. Super. 2006) (standard for appellate review of sentencing discretion)
Commonwealth v. Hallock, 603 A.2d 612 (Pa. Super. 1992) (presumption trial court considers all relevant sentencing factors with presentence report)