Commonwealth v. Christine, J., Aplt., 125 A.3d 394

Appellant was convicted of aggravated assault and REAP for a jailhouse attack in Northampton County Prison on June 8, 2009.
The victim, Thomas Missero, and appellant were inmates in the same cell; a razorblade attack occurred; a shank was later found in appellant's bed.
The Commonwealth sought to admit the shank under the similar-weapon exception and for other purposes; the trial court admitted it.
Appellant moved to admit Missero’s post-attack simple-assault conviction to rebut self-defense; the trial court denied.
On appeal, the Superior Court reversed in part, en banc review resulted in affirmance, and the Supreme Court granted allowance of appeal.
The Supreme Court ultimately upheld the trial court’s discretion to exclude Missero’s subsequent conviction and to admit the shank under proper theories.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of victim's subsequent conviction	Christine argues the conviction should prove victim was aggressor.	Commonwealth contends subsequent convictions lack similarity/time proximity to be probative.	Exclusion affirmed; subsequent conviction not admissible as similar‑in‑nature evidence
Admissibility of the shank under similar-weapon rule	Shank shows appellant's access/ability to fashion a weapon and rebut self-defense	Shank not linked to crime; admissible as similar weapon if foundation supports likelihood it was used	Admissibility affirmed under alternative theories; not error to admit to rebut self-defense

Commonwealth v. Amos, 445 Pa. 297 (Pa. 1971) (permissible to admit victim's prior aggression to show defendant's fear or victim as aggressor)
Commonwealth v. Beck, 485 Pa. 475 (Pa. 1979) (prior assault convictions imply aggressive propensity; persistent rule limited by context)
Commonwealth v. Mouzon, 617 Pa. 527 (Pa. 2012) (limits on admitting victim's prior aggression; similar-in-nature and timeliness considerations)
Commonwealth v. Robinson, 554 Pa. 293 (Pa. 1998) (similar-weapon rule; weapon need not be identical if foundation supports likelihood of use)
Commonwealth v. Ford, 451 Pa. 81 (Pa. 1973) (foundation supporting inference that weapon could have been used; admissibility over exact match)
Commonwealth v. Edwards, 588 Pa. 151 (Pa. 2006) (similar-weapon foundation required; probative value outweighs prejudice)
Commonwealth v. Lee, 541 Pa. 260 (Pa. 1995) (foundation to justify inference of weapon used; admissibility depends on linkage)
Commonwealth v. Williams, 640 A.2d 1251 (Pa. 1994) (weapon evidence admissible to show possible weapon similarity; weight to jury)