Com. v. Woodson, D.
Com. v. Woodson, D. No. 1576 EDA 2016
| Pa. Super. Ct. | Jul 25, 2017Background
- On September 19–20, 2014, Victim was assaulted and robbed by Darnell Woodson and two co-defendants; Victim was accused of “snitching.”
- Victim identified Appellant at the scene; police tracked Victim’s stolen cell phone to the defendants’ location and recovered items matching Victim’s property.
- Appellant was tried jointly with co-defendants; the jury convicted him of robbery, conspiracy to commit robbery, simple assault, and intimidation of a witness (18 Pa.C.S. §§ 3701, 903, 2701, 4952).
- The trial court sentenced Appellant to an aggregate term of 4 to 8 years’ incarceration; Appellant filed post-sentence motions and appealed.
- Appellant challenged (1) that the convictions were against the weight of the evidence (arguing Victim was not credible) and (2) that there was insufficient evidence to support the intimidation-of-a-witness conviction because the conduct related to past “snitching,” not a threat to refrain from future reporting/cooperation.
- The Superior Court affirmed, finding no abuse of discretion on the weight claim and that the evidence supported the witness-intimidation conviction because the defendants’ comments about “snitching” could reasonably be inferred to mean refraining from reporting or cooperating further with authorities.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight of the evidence as to all convictions | Commonwealth: convictions rest on Victim’s testimony, corroborated by recovered property and police investigation | Woodson: verdicts against the weight because Victim was incredible (admitted prior false accusation and lying about injuries) | Denied — trial court didn’t abuse discretion; credibility and weight are for the jury; evidence did not shock the conscience |
| Sufficiency of evidence for intimidation of a witness (18 Pa.C.S. § 4952) | Commonwealth: circumstantial evidence (timing of two robberies, “snitching” accusations, recovery of stolen items) supports that defendants intended to obstruct/impede criminal justice | Woodson: Victim only testified defendants accused him of past "snitching," not that they warned him to refrain from future cooperation — so § 4952 not met | Denied — evidence permitted reasonable inference defendants intended to impede/reporting or further cooperation; elements satisfied beyond a reasonable doubt |
Key Cases Cited
- Commonwealth v. Champney, 574 Pa. 435, 832 A.2d 403 (appellate review of weight-of-evidence claim limited; reversal only for palpable abuse of discretion)
- Commonwealth v. Jones, 874 A.2d 108 (standards for sufficiency review; circumstantial evidence may sustain conviction)
- Commonwealth v. Bullick, 830 A.2d 998 (sufficiency principles cited alongside Jones)
- Commonwealth v. Castillo, 585 Pa. 395, 888 A.2d 775 (Rule 1925(b) preservation and waiver principles)
- Commonwealth v. Lord, 553 Pa. 415, 719 A.2d 306 (Rule 1925(b) waiver doctrine)
- Commonwealth v. Hill, 609 Pa. 410, 16 A.3d 484 (Rule 1925(b) waivers may be raised sua sponte)
- Wirth v. Commonwealth, 626 Pa. 124, 95 A.3d 822 (appellate court may address waiver sua sponte)