Com. v. Williams, I.
2643 EDA 2015
| Pa. Super. Ct. | Oct 19, 2017Background
- On March 10, 2014, police stopped a Hyundai Sonata driven by Isiah Williams for speeding; Williams was the sole occupant and smelled of burnt marijuana.
- Williams could not produce a driver’s license; the car was a rental listed in his wife's name; Williams had the keys that also opened the trunk.
- An inventory search of the trunk revealed a backpack containing a loaded handgun and additional ammunition; Williams was prohibited from possessing firearms and had no carry permit.
- Williams was convicted after a waiver trial of unlawful possession (18 Pa.C.S. § 6105), carrying a firearm without a license (§ 6106), and carrying a firearm in Philadelphia (§ 6108); sentenced to 5–10 years on the possession count and 5 years probation consecutive on the license count.
- Defense witnesses (wife and brother) testified the car had been used by others and items had been placed in the trunk by a third party; the trial court found their testimony not credible and noted gaps in explanations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency: constructive possession of gun found in trunk | Commonwealth: Williams, as sole occupant who drove the car and had keys that opened the trunk, had the ability and intent to control the gun | Williams: gun belonged to someone else who used the rental; he lacked possession or control | Conviction affirmed — totality of circumstances supported constructive possession (ability + intent) |
| Weight of the evidence: verdict shocks justice | Commonwealth: testimony and circumstances supported verdict; credibility for trial court to resolve | Williams: only link was co-location in vehicle; evidence insufficient and unreliable | Trial court's credibility findings upheld; verdict not against weight of evidence |
| Compulsory joinder (18 Pa.C.S. § 110) — prior municipal traffic convictions bar later firearms prosecution? | Williams: summary traffic convictions tried and decided first; compulsory joinder should bar later related criminal charges | Commonwealth: traffic matters were within Municipal/Traffic Court jurisdiction, which does not trigger compulsory joinder bar | Denied — under controlling Superior Court precedent, traffic court jurisdiction under §1302 makes the earlier traffic dispositions not bar subsequent prosecutions |
Key Cases Cited
- Commonwealth v. Alford, 880 A.2d 666 (Pa. Super. 2005) (standard for sufficiency review)
- Commonwealth v. Gruff, 822 A.2d 773 (Pa. Super. 2003) (appellate review principles)
- Commonwealth v. Brown, 48 A.3d 426 (Pa. Super. 2012) (constructive possession required when contraband not on person)
- Commonwealth v. Parker, 847 A.2d 745 (Pa. Super. 2004) (definition and totality-of-circumstances test for constructive possession)
- Commonwealth v. Harvard, 64 A.3d 690 (Pa. Super. 2013) (ability and intent elements for constructive possession)
- Commonwealth v. Sanchez, 36 A.3d 24 (Pa. 2011) (credibility determinations lie with factfinder)
- Commonwealth v. Clay, 64 A.3d 1049 (Pa. 2013) (standard for appellate review of weight claims)
- Commonwealth v. Devine, 26 A.3d 1139 (Pa. Super. 2011) (weight-of-evidence standard)
- Commonwealth v. Reid, 77 A.3d 579 (Pa. 2013) (four-prong compulsory-joinder test)