Commonwealth v. Konias, 136 A.3d 1014

Konias was convicted at nonjury trial of first-degree murder and a consecutive robbery sentence for the 2012 Garda truck killing of Michael Haines.
He admitted shooting Haines but claimed self-defense; the Commonwealth presented evidence of a planned robbery and lack of struggle inside the truck.
The Garda truck had three compartments; the hopper area contained the victim’s chair and money, accessible only from the exterior.
On the day of the homicide, Konias moved money to the hopper instead of the rear storage area, shot Haines in the back of the head, then fled with over $2.3 million.
He was apprehended in Florida in 2013; later motions for funding forensic experts were denied for lack of financial information; the court imposed life without parole plus a 10–20 year term.
The appellate court affirmed, addressing indigency funding, admissibility of Detective Sherwood’s statements, and the weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused its discretion by denying expert funding without a hearing	Konias contends indigency merits funding for experts to counter evidence.	Konias argues the court should have held a hearing to assess need and indigency.	No abuse; mere indigency claims require some financial detail and a hearing if needed.
Whether Detective Sherwood could testify about a struggle inside the truck	Sherwood’s lay opinion was improper as speculative and outside personal knowledge.	Testimony was within admissible lay understanding of the scene after the fact.	Harmless; failure to object waived any issue, and the record shows no impact on verdict.
Whether the verdict was against the weight of the evidence	Evidence supported self-defense; murder verdict against the weight of the evidence.	Evidence showed no struggle and lethal force was unjustified; verdict not weight-shocked.	Not against the weight of the evidence; trial court’s credibility determinations stand.

Commonwealth v. Curnutte, 871 A.2d 839 (Pa. Super. 2005) (indigent defense funding not automatic; court discretion)
Commonwealth v. Sweeney, 533 A.2d 473 (Pa. Super. 1987) (affirmative duty to provide protections to indigents)
Ake v. Oklahoma, 470 U.S. 68 (1985) (due process right to expert assistance where necessary)
Commonwealth v. Cannon, 954 A.2d 1222 (Pa. Super. 2008) (indigency and appointment of counsel/experts; hearing may be required)
Commonwealth v. Stokes, 78 A.3d 644 (Pa. Super. 2013) (proper preservation of evidentiary issues; waiver due to objection)
Commonwealth v. Morales, 91 A.3d 80 (Pa. 2014) (weight-of-the-evidence standard; deference to trial court)
Commonwealth v. Sanchez, 36 A.3d 24 (Pa. Super. 2011) (credibility and weight of evidence; fact-finder’s role)
Commonwealth v. Griffin, 684 A.2d 589 (Pa. Super. 1996) (require timely and specific trial objections to preserve issues)
Commonwealth v. Blackham, 909 A.2d 315 (Pa. Super. 2006) (credibility determinations lie with the finder of fact)