Com. v. Williams, T., Com. v. Williams, T. No. 701 EDA 2016

On March 10, 2013, Appellant Tony L. Williams (adult) allegedly awakened his 13‑year‑old cousin Z.H., asked her to touch his genitals, touched her vagina over her clothes twice, attempted to grab her waist, and told her “if [she] wanted anything [she] could get it.”
Z.H. reported the incident to police the next day and gave a statement; bench trial held January 23, 2015.
Trial court convicted Williams of unlawful contact with a minor (18 Pa.C.S. §6318(a)(1)), corruption of minors (§6301(a)(1)(i)), and indecent assault (§3126(a)(1)).
Sentencing was deferred for a PSI and SOAB assessment; on November 23, 2015 the court designated Williams a sexually violent predator (SVP) after expert testimony and sentenced him to 1.5–5 years’ incarceration plus five years’ sex offender probation.
Post‑sentence motion denied; appeal raised weight and sufficiency of the evidence, SVP designation, and discretionary sentencing claims; appellate court affirmed.

Issue	Plaintiff's Argument (Commonwealth)	Defendant's Argument (Williams)	Held
1. Weight of the evidence supporting convictions	Trial court’s credibility findings should be upheld; victim’s testimony was credible	Weight of the evidence is against conviction; victim’s statements inconsistent/implausible	Affirmed: trial court did not abuse discretion; verdict not against the weight of the evidence
2. Sufficiency of the evidence for convictions	Victim’s uncorroborated testimony and related facts suffice to prove elements beyond a reasonable doubt	Evidence insufficient because too many people in room and inconsistencies undermine proof	Waived for lack of specificity in Rule 1925(b); merits rejected—evidence (including victim testimony) sufficient
3. SVP designation sufficiency	Expert testimony and records established mental abnormality and risk by clear and convincing evidence	Commonwealth failed to prove SVP elements by clear and convincing evidence	Waived for Rule 1925(b) deficiency; on merits, affirmed—clear and convincing evidence supported SVP finding
4. Discretionary aspects of sentence (excessive/above guidelines)	Court failed to state reasons on record; sentence excessive	Sentence within court’s discretion; court considered PSI, SOAB, counsel arguments, allocution	Not preserved at sentencing; even on merits, no abuse of discretion—court adequately considered factors and PSI speaks for itself

Commonwealth v. Rayner, 153 A.3d 1049 (Pa. Super. 2016) (standard and deference for weight‑of‑the‑evidence review)
Commonwealth v. Freeman, 128 A.3d 1231 (Pa. Super. 2015) (Rule 1925(b) specificity requirement for sufficiency challenges)
Commonwealth v. Trippett, 932 A.2d 188 (Pa. Super. 2007) (uncorroborated sexual‑assault victim testimony can support conviction)
Commonwealth v. Feucht, 955 A.2d 377 (Pa. Super. 2008) (standard of review and burden for SVP designation)
Commonwealth v. Antidormi, 84 A.3d 736 (Pa. Super. 2014) (deference to sentencing court and presumption that PSI informed sentencing)