Com. v. Williams-Keyes, K., 1431 MDA 2015

Appellant Kabril I. Williams-Keyes committed a violent assault on Ernestine Pearson on Aug. 5–6, 2014 (punching, kicking, taking her phone, dousing her with grease/alcohol, threatening to set her on fire); victim sustained multiple injuries.
Charged via complaint; aggravated assault count (second-degree felony) held for court and docketed at 4138 of 2014; bail condition included no contact with Pearson.
On Dec. 31, 2014, Appellant returned to Pearson’s residence in violation of bail, assaulted her and threatened her with a knife, bit her child’s finger, and then led police on a high-speed chase with Pearson and two children in the vehicle; 20 counts filed and docketed at 877 of 2015.
May 19, 2015: Appellant pled guilty in both matters—one aggravated assault (4138/2014); in 877/2015 pled to one aggravated assault and two counts of attempted aggravated assault of a child (Commonwealth withdrew remaining counts).
July 1, 2015: Sentenced within guideline ranges—aggregate 10 to 20 years (120–240 months) after consecutive terms; post-sentence motion denied and timely appeal filed.

Issue	Appellant's Argument	Commonwealth/Trial Court's Argument	Held
Whether the sentence was improper under law (discretionary aspects)	Sentence was excessive, above mitigated guideline ranges, court failed to weigh mitigating factors	Sentence was within guidelines; court considered PSI and factors; Appellant simply disagrees with weight	No substantial error; sentence affirmed
Whether denial of post-sentence motion was erroneous	Trial court erred by denying reconsideration/modification based on mitigating facts (remorse, addiction, mental health, family, employment)	Court reviewed PSI and properly exercised discretion	Denial affirmed; no abuse of discretion
Whether a substantial question exists that guideline application produced a clearly unreasonable aggregate sentence	Consecutive sentences produced an unduly harsh aggregate result	Sentences were within guidelines and circumstances justified consecutive terms	Not a substantial question as pleaded; aggregate not unduly harsh
Whether the sentence was manifestly excessive/unreasonable	Aggregate sentence was manifestly excessive given mitigating circumstances and rehabilitation potential	Sentencing court considered nature of offenses, defendant history, and PSI; choice to impose consecutive terms was reasonable	No reversible error; sentence within guideline reason and affirmed

Commonwealth v. Griffin, 65 A.3d 932 (Pa. Super. 2013) (four-part test for appellate review of discretionary sentencing claims)
Commonwealth v. Dodge, 77 A.3d 1263 (Pa. Super. 2013) (when consecutive within-guideline sentences may raise a substantial question)
Commonwealth v. Moury, 992 A.2d 162 (Pa. Super. 2010) (consecutive sentences raise substantial question only in extreme circumstances)
Commonwealth v. Caldwell, 117 A.3d 763 (Pa. Super. 2015) (excessive sentence claim paired with failure-to-consider mitigating factors can present a substantial question)
Commonwealth v. Devers, 546 A.2d 12 (Pa. 1988) (presumption that sentencing court considered information in presentence report)