Com. v. Williamson, J., 330 A.3d 407

Jonah Raheem Williamson was convicted by a jury in Cumberland County, PA, of aggravated assault (causing serious bodily injury) and recklessly endangering another person following an incident where he allegedly stabbed his former girlfriend, Likitia Dotson, at a hotel in December 2021.
Evidence at trial included Dotson's statements immediately after the stabbing, hospital records, officer testimony, and recorded prison phone calls between Williamson and Dotson.
At trial, Dotson provided contradictory testimony, denying that Williamson stabbed her and attributing memory lapses to alcoholism and the passage of time.
The trial court admitted the prison phone calls, finding them both properly authenticated and subject to hearsay exceptions under Pennsylvania evidentiary rules.
Williamson was sentenced to 9 ½ to 19 years' imprisonment, with a deadly weapon enhancement applied to his sentence for aggravated assault.
On appeal, Williamson challenged the admission of the prison calls, the sufficiency and weight of the evidence regarding serious bodily injury, and the application of the deadly weapon enhancement, among other issues.

Issue	Williamson's Argument	Commonwealth's Argument	Held
Admission of recorded prison phone calls	Calls contained hearsay; not properly excepted; not sufficiently authenticated.	Calls authenticated; admissible as state-of-mind/physical condition; used to show plan to fabricate story.	Affirmed admission; falls under hearsay exceptions and properly authenticated.
Sufficiency of evidence—aggravated assault	Evidence insufficient to prove serious bodily injury or intent/recklessness required.	Extensive evidence of stab wounds, risk of death; medical and witness testimony supported serious injury.	Evidence sufficient; jury's finding of serious injury and reckless conduct upheld.
Weight of the evidence	Verdict against the weight, especially given contradictory victim testimony and supposed unreliability of evidence.	Jury properly weighed credibility; full record supports their finding.	No abuse of discretion; verdict not so contrary to evidence as to shock the conscience.
Deadly weapon enhancement	Enhancement improper since jury acquitted of aggravated assault with deadly weapon and knife was never found.	Standard is preponderance of evidence (not beyond reasonable doubt); testimony and other evidence showed use of knife.	Enhancement affirmed; sufficient evidence even without weapon recovery.

Commonwealth v. Harrington, 262 A.3d 639 (Pa. Super. 2021) (standard for reviewing evidentiary rulings is abuse of discretion)
Commonwealth v. Mollett, 5 A.3d 291 (Pa. Super. 2010) (scope/plenary review of evidentiary discretion)
Commonwealth v. Burton, 2 A.3d 598 (Pa. Super. 2010) (reckless conduct suffices for aggravated assault if serious injury is caused)
Commonwealth v. Patrick, 933 A.2d 1043 (Pa. Super. 2007) (recklessness standard in aggravated assault)
Commonwealth v. McKeithan, 504 A.2d 294 (Pa. Super. 1986) (deadly weapon enhancement applies without weapon recovery)
Commonwealth v. Raybuck, 915 A.2d 125 (Pa. Super. 2006) (knives are obvious deadly weapons under sentencing guidelines)