Commonwealth v. Brown, 52 A.3d 320

Brown was convicted on sixteen counts of unlawfully prescribing controlled substances to six patients (2002–2004) as a licensed physician and received an aggregate eight-to-sixteen-year sentence.
The Commonwealth sought to introduce decades-old bad acts, including fraud in obtaining Brown’s medical degree and license before 1984, under the common law res gestae exception.
The trial court dismissed most charges, allowed six patients’ treatment evidence, and initially barred evidence of Brown’s alleged pre-1984 license fraud, but later permitted the license-fraud evidence after reconsideration.
The prosecution’s theory and opening/closing arguments framed the case around Brown’s alleged improper receipt of his medical degree and forged/altered records to obtain his license.
Expert testimony from Dr. Vilensky portrayed Brown’s treatment as not in accord with accepted standards, while Brown’s own expert offered contrary views, yet the jury accepted the Commonwealth’s view.
On appeal, the court found insufficient grounds to disturb the sufficiency of the evidence but reversed and remanded for a new trial due to improper admission of decades-old bad acts evidence under res gestae.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of decades-old bad acts	Brown contends res gestae allowed improper legacy acts.	Commonwealth argues acts complete the story and show bad faith.	Abuse of discretion; decadelong bad acts not admissible under res gestae.
Pre-trial evidentiary rulings on licensing fraud	Allowance of license-fraud evidence prejudicially taints trial.	Evidence relevant to conduct and intent in prescribing.	Reversed due to improper evidentiary balancing; new trial ordered.
Sufficiency of the evidence to prove bad-faith prescribing	Evidence showed bad faith in prescribing under standard of care.	Expert testimony supported compliance with accepted care.	Sufficiency upheld; however, this issue was deemed non-decisive after evidentiary reversal.
Relation of the drug-prescribing charges to prior acts	Prior acts demonstrate bad faith linking to current charges.	No direct temporal or causal connection; advanced argument unused.	Not addressed separately after res gestae ruling; new trial required.

Commonwealth v. Aikens, 990 A.2d 1181 (Pa. Super. 2010) (abuse-of-discretion standard for evidentiary rulings)
Commonwealth v. Moser, 999 A.2d 602 (Pa. Super. 2010) (abuse-of-discretion review for motion in limine)
Lark, 543 A.2d 491 (Pa. Super. 1988) (res gestae and complete-story rationale; proximity in time/place considerations)
Sherwood, 982 A.2d 483 (Pa. 2009) (res gestae admissibility; pattern of abuse as relevant context)
Brown v. Commonwealth, 342 A.2d 84 (Pa. 1975) (res gestae framework; similar-transaction analysis)
Coyle, 203 A.2d 782 (Pa. 1964) (early articulation of res gestae limits)
Goersen v. Commonwealth, 99 Pa. 388 (1882) (limits and purposes for other-crimes evidence; res gestae lineage)
Shaffner v. Commonwealth, 72 Pa. 60 (1872) (caution against admitting other-crimes evidence without clear connection)