Commonwealth v. Hansley
24 A.3d 410
| Pa. Super. Ct. | 2011Background
- 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- The trial court sentenced Hansley to 5–10 years’ imprisonment plus 2 years’ probation; post-sentence motions were withdrawn.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)
