Commonwealth v. Johnson
100 A.3d 207
Pa. Super. Ct.2014Background
- Appellant Sincerity Johnson was convicted by a non-jury trial of hindering apprehension or prosecution and obstructing the administration of law stemming from harboring a fugitive in her apartment.
- Police, FBI, and U.S. Marshals arrived at 633 West Rittenhouse Street to arrest Rodney Thompson; Johnson opened the door after a delay and allowed Thompson to flee via the building’s roof.
- Johnson was charged with hindering apprehension (a felony initially) and obstructing administration of law (a misdemeanor).
- The trial court found Johnson guilty and sentenced her to twelve months reporting probation on each offense, running concurrently.
- On appeal, Johnson challenged the legal sufficiency of both convictions, prompting appellate review of the hindering element and the obstruction element.
- The Superior Court reversed the hindering conviction for lack of proof that Thompson was being sought for a crime or probation/parole violation, but affirmed the obstruction conviction based on physical interference in delaying entry.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is hindering proven without showing Thompson’s underlying crime | Johnson argues no proof Thompson was being sought for a crime or probation violation. | Commonwealth contends underlying crime not required to prove hindering; evidence of intent suffices. | Hindering reversed; underlying crime not proven. |
| Is obstruction proven by Johnson’s delay and false statements | Johnson’s delay was incidental; no physical interference or obstruction shown. | Delay and misstatements constituted obstruction to police entry and execution of the warrant. | Obstruction affirmed; evidence supports physical interference/obstacle to execution. |
Key Cases Cited
- Commonwealth v. Conception, 657 A.2d 1298 (Pa. Super. 1995) (physical interference can sustain § 5101 conviction)
- Commonwealth v. Reed, 851 A.2d 958 (Pa. Super. 2004) (interference to execute duty may be non-physical)
- Commonwealth v. Snyder, 60 A.3d 165 (Pa. Super. 2013) (physical interference standard for obstruction of justice)
- Commonwealth v. Patterson, 390 A.2d 784 (Pa. Super. 1978) (whether aiding of another’s crime proves hindering)
- Commonwealth v. Lore, 487 A.2d 841 (Pa. Super. 1984) (concept of aider’s culpability focusing on state of mind)