Com. v. Williams, R.
255 WDA 2017
| Pa. Super. Ct. | Sep 21, 2017Background
- On June 4–5, 2016, J.L. met Williams at a bar, rode with him to a gas station, asked to be dropped off where she lived, but Williams drove about one mile in the opposite direction to a secluded spot.
- Williams punched J.L. when she tried to exit, threatened to shoot her, pinned and mounted her, and had sex with her; J.L. testified she was bitten, strangled, and had a hard metal object inserted into her rectum, requiring emergency surgery (colostomy) for impalement injuries.
- Williams admitted to consensual intercourse (disputed), and to striking J.L. up to five times claiming she stole his money.
- After learning police were looking for him, Williams set his car on fire; officers recovered the clothes he wore and a lug wrench believed to be the metal object; Williams checked into a hospital under a false name.
- A jury convicted Williams of kidnapping, simple assault, reckless burning, and tampering with evidence, but acquitted him of aggravated assault, rape, and involuntary deviate sexual intercourse. He was sentenced to aggregate terms totaling 13 years 3 months to 31 years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for kidnapping under 18 Pa.C.S. § 2901(a)(3) | Commonwealth: moving victim ~1 mile to secluded roadside and isolating her supported kidnapping to terrorize/inflict injury. | Williams: movement/confinement not a "substantial distance" or substantial period/place of effective isolation. | Court: Affirmed — ~1 mile to secluded area and threats/punching created "place of isolation;" evidence sufficient. |
| Admission of two post-assault genital photographs | Commonwealth: photos relevant to injuries and aided medical testimony. | Williams: photographs inflammatory, prejudicial, irrelevant. | Court: Affirmed — photos were inflammatory but of essential evidentiary value; precautions limited prejudice. |
| Merger of simple assault and kidnapping for sentencing | Williams: offenses merge because they arose from a single act. | Commonwealth: separate acts (punching/isolation v. strangling/biting) are distinct acts beyond elements of the other. | Court: Affirmed — crimes did not arise from a single act; no merger. |
| Discretionary sentencing (consecutive maximums) | Williams: sentence excessive; court punished him for acquitted offenses. | Commonwealth: court considered § 9721 factors, criminal history, violent nature, and need for protection/rehabilitation. | Court: Affirmed — sentencing court did not abuse discretion; considered required factors and records. |
Key Cases Cited
- Commonwealth v. Talbert, 129 A.3d 536 (Pa. Super. 2015) (sufficiency review standard)
- Commonwealth v. Hughes, 399 A.2d 694 (Pa. Super. 1979) (substantial distance/place of isolation not strictly measured by linear distance/time)
- Commonwealth v. Chester, 587 A.2d 1367 (Pa. 1991) (evaluate movement "under the circumstances")
- Commonwealth v. Malloy, 856 A.2d 767 (Pa. 2004) (kidnapping analyses and precedent)
- Commonwealth v. Jenkins, 687 A.2d 836 (Pa. Super. 1996) (definition of "place of isolation")
- Commonwealth v. Tharp, 830 A.2d 519 (Pa. 2003) (admissibility test for inflammatory photographs)
- Commonwealth v. Pruitt, 951 A.2d 307 (Pa. 2008) (photographs may supplement expert testimony and are not merely cumulative)
- Commonwealth v. Pettersen, 49 A.3d 903 (Pa. Super. 2012) (multiple distinct criminal acts do not merge for sentencing)
- Commonwealth v. Evans, 901 A.2d 528 (Pa. Super. 2006) (procedural requirements and review for discretionary sentencing)
- Commonwealth v. Walls, 926 A.2d 957 (Pa. 2007) (sentencing factors and reasonableness review)