History
  • No items yet
midpage
Commonwealth v. Hansley
24 A.3d 410
| Pa. Super. Ct. | 2011
Read the full case

Background

  • Appellant Hansley was convicted by a Lancaster County jury of first-degree robbery.
  • Target loss prevention observed Hansley entering with a bag, handling merchandise, and moving DVDs around the store.
  • Hansley exchanged items at guest services, passed all points of sale, and alarm tripped when leaving.
  • A knife was observed in Hansley’s pocket during the struggle with store security, and he brandished it toward a security guard.
  • Police identified Hansley in a photographic lineup and the Commonwealth charged robbery and related offenses.
  • The trial court sentenced Hansley to 5–10 years’ imprisonment plus 2 years’ probation; post-sentence motions were withdrawn.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence for robbery Hansley argues evidence did not prove robbery beyond a reasonable doubt. Commonwealth contends the evidence showed threat and imminent danger supporting robbery. Sufficient evidence supported robbery; intent and threat shown.
Continuance to interview hospitalized witness Denial of continuance denied defense time to consult a potential witness. Court abused discretion by denying requested continuance on second trial day. No abuse of discretion; denial proper and not prejudicial.
Juror justification/self-defense instruction Trial court erred in refusing to instruct on justification and self-defense. Evidence did not satisfy three-element test for self-defense/justification. Court properly refused instruction; no error.

Key Cases Cited

  • Commonwealth v. Jones, 874 A.2d 108 (Pa. Super. 2005) (sufficiency standard—view evidence in light most favorable to verdict)
  • Commonwealth v. Bullick, 830 A.2d 998 (Pa. Super. 2003) (sufficiency review framework)
  • Commonwealth v. Mayfield, 585 A.2d 1069 (Pa. Super. 1991) (three elements for self-defense instruction)
  • Commonwealth v. Reeves, 907 A.2d 1 (Pa. Super. 2006) (waiver doctrine for Rule 1925 issues)
  • Commonwealth v. Dowling, 778 A.2d 683 (Pa. Super. 2001) (waiver for inadequately developed claims)
Read the full case

Case Details

Case Name: Commonwealth v. Hansley
Court Name: Superior Court of Pennsylvania
Date Published: Jun 22, 2011
Citation: 24 A.3d 410
Court Abbreviation: Pa. Super. Ct.