Commonwealth v. Jones
172 A.3d 1139
| Pa. Super. Ct. | 2017Background
- In June 2014 police responded to a domestic disturbance at Appellant Travis H. Jones’s home; Jones admitted he accidentally shot the victim.
- Police recovered a .44 Magnum revolver with an obliterated serial number and a shotgun; ballistics linked the revolver to the victim’s wound.
- Jones was tried and convicted on two counts of Possession of a Firearm Prohibited (18 Pa.C.S. § 6105) after the court found he had a prior New Jersey manslaughter conviction.
- In a separate jury trial Jones was convicted of Possession of a Firearm with an Altered Serial Number (18 Pa.C.S. § 6110.2); the jury acquitted on tampering with evidence.
- The Commonwealth introduced documentary evidence of the prior New Jersey conviction and fingerprint comparison evidence tying Jones to the New Jersey arrest record; a firearms expert testified the serial number had been obliterated and could not be restored.
- Jones received an aggregate sentence of 16 to 30 years; he appealed arguing insufficiency of the evidence on both the §6105 (prior conviction identity) and §6110.2 (mens rea for altered serial number) convictions.
Issues
| Issue | Appellant's Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Sufficiency to prove prior violent conviction for §6105 | Documentary evidence alone did not conclusively prove Jones was the person convicted of manslaughter | Documents plus fingerprint comparison and ID card sufficiently tied Jones to the NJ conviction | Affirmed: totality of evidence proved identity and prior manslaughter conviction |
| Mens rea for possession of firearm with altered serial number (§6110.2) | Commonwealth failed to prove Jones knew the serial number was obliterated or had requisite culpability | Possession, use, hiding of the gun and degree of obliteration permitted inference of guilty knowledge | Affirmed: jury could infer knowledge; Commonwealth proved requisite culpability (intent/knowledge/recklessness) |
Key Cases Cited
- Commonwealth v. Murray, 83 A.3d 137 (Pa. 2013) (standard of review for sufficiency challenges)
- Commonwealth v. Pruitt, 951 A.2d 307 (Pa. 2008) (sufficiency review and inferences to be drawn in favor of Commonwealth)
- Commonwealth v. Markman, 916 A.2d 586 (Pa. 2007) (circumstantial evidence can sustain conviction)
- Commonwealth v. Payne, 463 A.2d 451 (Pa. Super. 1983) (proof of prior conviction required under §6105)
- Commonwealth v. Gravelle, 55 A.3d 753 (Pa. Super. 2012) (statutory interpretation standard of review)
- Commonwealth v. Gallagher, 924 A.2d 636 (Pa. 2007) (mens rea generally required absent legislative direction)
- Commonwealth v. Shore, 393 A.2d 889 (Pa. Super. 1978) (possession and attempt to discard firearm with altered serial number can show guilty knowledge)