Com. v. Williamson, R., Com. v. Williamson, R. No. 1081 WDA 2016

On Nov. 24, 2015, Williamson was found intoxicated and was arrested for public drunkenness; at the station he forcefully resisted and bit Officer Gabriel Carducci, causing an open wound.
Commonwealth charged Williamson with aggravated assault (against an officer), resisting arrest, and public drunkenness; a jury convicted him on June 9, 2016.
At sentencing (July 12, 2016) the court, with a PSI and psychiatric evaluations in the record, revoked prior probation on a separate docket and imposed consecutive terms: 27–54 months (aggravated assault), 9–18 months (resisting arrest), plus 1–2 years on the revoked docket — aggregate 4–8 years in a state correctional institution.
Williamson filed a post-sentence motion claiming the court failed to adequately account for his mental-health treatment needs and that the consecutive, high-end sentence was manifestly excessive; the court denied relief and Williamson appealed.
The Superior Court reviewed whether Williamson raised a substantial question about the discretionary aspects of sentencing and affirmed, adopting the trial court’s detailed explanation that the sentence balanced community protection and treatment needs given Williamson’s violent conduct while on supervision and his failure to benefit from prior county-level programs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence (consecutive, high-end standard range) was manifestly excessive and failed to account for mental-health needs	Williamson: sentence unreasonable; court ignored or underweighted his need for high-intensity mental-health treatment and rehabilitation	Commonwealth/Trial Ct: court considered PSI, evaluations, and treatment options but properly prioritized public safety given violent assault while on supervision and prior noncompliance	Court affirmed: no abuse of discretion; trial court considered relevant factors and reasonably concluded incarceration best protected public and would provide needed treatment

Commonwealth v. Sierra, 752 A.2d 910 (Pa. Super. 2000) (discretionary sentencing matters not appealable as of right)
Commonwealth v. Mouzon, 812 A.2d 617 (Pa. 2002) (Rule 2119(f) requirement and when a substantial question is raised)
Commonwealth v. Cruz-Centeno, 668 A.2d 536 (Pa. Super. 1995) (bare claim that court failed to consider factors does not raise a substantial question)
Commonwealth v. Walls, 926 A.2d 957 (Pa. 2007) (standard for abuse of discretion in sentencing review)
Commonwealth v. Coolbaugh, 770 A.2d 778 (Pa. Super. 2001) (scope of review after probation revocation)
Commonwealth v. Lloyd, 878 A.2d 867 (Pa. Super. 2005) (consecutive vs. concurrent sentencing lies within sentencing court’s discretion)