Com. v. Woodson, R.
2444 EDA 2015
Pa. Super. Ct.Dec 27, 2017Background
- On Jan. 24, 2014 Rudolph Woodson was arrested after the victim was found with multiple stab and slash wounds (severed internal jugular, facial nerve injury) and required emergency treatment.
- Police observed blood trail at Woodson’s home and recovered a knife; officers testified Woodson admitted stabbing the victim and directed them to the knife’s location.
- Woodson waived a jury and proceeded to a bench trial; the court convicted him of attempted murder, aggravated assault, simple assault, REAP, and possessing an instrument of crime.
- Sentencing: attempted murder 15–40 years, consecutive PIC 2.5–5 years, consecutive REAP 1–2 years; aggregate 18.5–47 years.
- On appeal Woodson argued the 40-year maximum for attempted murder was illegal because the information did not charge attempted murder resulting in serious bodily injury (SBI), so he lacked notice and the factfinder was not asked to find SBI beyond a reasonable doubt; other issues (sufficiency, weight, merger, discretionary sentencing) were also raised.
Issues
| Issue | Commonwealth's Argument | Woodson's Argument | Held |
|---|---|---|---|
| Legality of 40-year maximum for attempted murder under 18 Pa.C.S. § 1102(c) | 40-year maximum lawful because court (as bench factfinder) found attempted murder caused serious bodily injury; defendant was informed of 40-year maximum. | Sentence illegal because information charged attempted murder generally and did not allege SBI; defendant lacked notice and factfinder did not make the required finding beyond a reasonable doubt. | The 40-year maximum was lawful: trial court explicitly found beyond a reasonable doubt that Woodson intended to kill and caused SBI, so Apprendi concerns are satisfied in a bench trial. |
| Whether the factfinder made the required SBI finding | The trial court, as factfinder, stated it found that defendant caused serious bodily injury; that suffices. | SBI was not charged in the information; prior precedent requires the jury to find SBI beyond a reasonable doubt when imposing the higher maximum. | Court held the bench trial judge made an express SBI finding at verdict, distinguishing this from cases where a jury never decided SBI. |
| Notice that Commonwealth sought 40-year maximum / alleged SBI | Woodson was placed on notice: complaint alleged multiple stab wounds requiring medical attention; waiver colloquy informed him of a 40-year maximum; he defended on self-defense. | Information did not allege SBI or the 40-year statutory basis, so Woodson lacked notice he needed to defend the SBI element. | Court found adequate notice given the complaint’s factual allegations, the written and oral colloquies advising a 40-year maximum, and Woodson’s actual trial defense. |
| Sufficiency / weight of evidence; merger and discretionary sentencing issues | Evidence (victim testimony, police, and surgeons) established intent to kill, SBI, and defeated self-defense; separate episodes supported REAP and PIC; sentencing discretion and merger claims waived where post-sentence motions were not filed. | Argued insufficiency/weight and sentencing errors (as raised in Anders brief). | Evidence sufficient to support convictions; weight claim waived (no post-trial motion) and meritless; REAP did not merge because attacks were discrete; discretionary-sentencing claims waived (no post-sentence motion). |
Key Cases Cited
- Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (any fact that increases the penalty beyond the statutory maximum must be submitted to a jury and proved beyond a reasonable doubt, except prior convictions)
- Commonwealth v. Barnes, 167 A.3d 110 (Pa. Super. 2017) (40-year attempted-murder maximum requires SBI finding and defendant notice; jury must decide SBI)
- Commonwealth v. Johnson, 910 A.2d 60 (Pa. Super. 2006) (Apprendi requires jury find SBI for 40-year max; absence of charge/notice renders 40-year sentence illegal)
- Commonwealth v. Reid, 867 A.2d 1280 (Pa. Super. 2005) (40-year max upheld where defendant pleaded to a charge reflecting the 40-year grading and did not contest the factual basis showing SBI)
- Commonwealth v. DeJesus, 860 A.2d 102 (Pa. 2004) (specific intent to kill may be inferred from use of a deadly weapon on a vital part of the body)