Commonwealth v. Chine
40 A.3d 1239
| Pa. Super. Ct. | 2012Background
- Appellant Schneider Chine was convicted by a jury of first-degree murder and possession of an instrument of crime for the October 28, 2008 shooting of Jaleel LovingThomas.
- The incident occurred after a confrontation at Lundi’s West Albanus Street residence where Lundi and others demanded information about a robber; Thomas attempted to mediate.
- Appellant pulled a gun and fired three shots at the unarmed victim’s head from behind, then fired at Thomas; two bullets hit the victim, and Appellant fled after running out of bullets.
- At arrest on November 30, 2008, Appellant admitted killing the victim and gave a statement asserting perceived imminent threat and intent to kill to protect himself.
- The trial court sentenced Appellant to life imprisonment on February 7, 2011; Appellant appealed, challenging sufficiency and weight of the evidence and requests for self-defense and voluntary-manslaughter instructions.
- The Superior Court affirmed, addressing sufficiency, weight, and the propriety of jury instructions regarding self-defense and voluntary manslaughter.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for first-degree murder | Chine lacked malice and specific intent to kill. | Commonwealth failed to prove malice beyond a reasonable doubt; evidence shows self-defense. | Evidence supports malice and intent to kill; conviction affirmed. |
| Weight of the evidence | Verdict against the weight suggests credibility issues favoring Appellant. | The court should reassess credibility; verdict shocks conscience. | No basis to disturb credibility; weight claim denied; judgment affirmed. |
| Self-defense jury instruction | Trial court should have instructed on self-defense. | Self-defense justification existed as a matter of law. | No evidentiary basis to support self-defense; instruction not required. |
| Voluntary manslaughter instruction (unreasonable belief) | Instruction should have been given on unreasonable belief of danger. | Not properly developed on appeal; waived. | Claim waived for lack of development; instruction not required. |
Key Cases Cited
- Commonwealth v. Walsh, 36 A.3d 613 (Pa.Super.2012) (standard for reviewing sufficiency of circumstantial evidence)
- Commonwealth v. Briggs, 608 Pa. 430 (Pa. 2011) (deadly-weapon infers malice and intent from vital body part)
- Commonwealth v. Cruz, 919 A.2d 279 (Pa.Super.2007) (back-shot murder supports malice inference)
- Commonwealth v. Houser, 18 A.3d 1128 (Pa.2011) (disproving self-defense claim; jury does not have to believe defendant)
- Commonwealth v. Truong, 36 A.3d 592 (Pa.Super.2012) (duty to retreat and other self-defense limitations)
- Widmer, 744 A.2d 745 (Pa.2000) (weight-of-the-evidence standard; appellate discretion)
- Commonwealth v. Holley, 945 A.2d 241 (Pa.Super.2008) (credibility assessment is for trier of fact)
- Commonwealth v. Griscavage, 517 A.2d 1256 (Pa.1986) (credibility determinations within appellate review)
- Commonwealth v. Bozic, 997 A.2d 1211 (Pa.Super.2010) (reaffirming weight-of-the-evidence review standard)
- Commonwealth v. Manley, 985 A.2d 256 (Pa.Super.2009) (reaffirming appellate deference to juries on credibility)
- Commonwealth v. Sanchez, 36 A.3d 24 (Pa.2011) (elements of first-degree murder and malice with intent)