Commonwealth v. Garland, 63 A.3d 339

Appellant and Ronald Bradley drove past a group on Pratt Street, brandished firearms, and opened fire, killing Colbert and injuring others.
Fourteen bullet casings were recovered at the scene, with both .40 and .45 caliber bullets involved; a .45 handgun was found at Bradley’s house.
Golphin identified Appellant from a photo array; Appellant and Bradley fled in the same vehicle.
March 13, 2009, officers pursued Appellant, who discarded a loaded .380 handgun; Appellant gave a false name before arrest.
Appellant gave a post-arrest statement admitting participation in the shooting but claiming Bradley provoked the incident.
Appellant moved to suppress both the firearm and the statement; the trial court denied the suppression motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Waiver of suppression challenge for firearm	Appellant contends suppression should be reviewed.	Commonwealth argues waiver under Rule 1925(b) and questions presented.	Waived.
Voluntariness of Appellant's statement	Statement was involuntary due to 8+ hour delay and isolation.	Statement was voluntary under totality of circumstances.	Voluntary; suppression denied.
Sufficiency of evidence for third-degree murder	Evidence insufficient to prove malice or intent.	Evidence supported malice/recklessness sufficient for third-degree murder.	Evidence sufficient; conviction sustained.

Commonwealth v. Hill, 609 Pa. 410, 16 A.3d 484 (Pa. 2011) (waiver for Rule 1925(b) issues exceptions noted)
Commonwealth v. Ligons, 971 A.2d 1125 (Pa. 2009) (standard for reviewing suppression rulings; factual findings deference)
Commonwealth v. Housman, 986 A.2d 822 (Pa. 2009) (totality of circumstances in voluntariness analysis)
Commonwealth v. Perez, 845 A.2d 779 (Pa. 2004) (time not determinative; focus on voluntariness totality)
Commonwealth v. Truong, 36 A.3d 592 (Pa. Super. Ct. 2012) (malice inferred from circumstances and use of deadly weapon)