Commonwealth v. Lofton
57 A.3d 1270
| Pa. Super. Ct. | 2012Background
- Lofton appeals after being convicted of second-degree murder and related offenses; he received a life sentence without parole for the murder.
- The murder occurred on Christmas 2007; the victim Andrew Jackson was shot multiple times during a robbery attempt by Lofton and two co-defendants.
- Witnesses included in-court testimony and out-of-court statements by J.D., a 15-year-old, and Terrance Farley; their statements were used to support Lofton's convictions.
- Lofton challenged the verdict as against the weight of the evidence and argued the sentencing violated Eighth Amendment and due process because he was a juvenile.
- The trial court imposed a mandatory life term; Lofton preserved issues for appeal, including the Miller v. Alabama sentencing issue.
- The superior court vacated Lofton’s sentence and remanded for resentencing in light of Miller and related Pennsylvania statutory guidance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the verdict was against the weight of the evidence | Lofton argues inconsistent statements render the verdict unreliable | Commonwealth contends the weight claim is preserved and credibility for the jury to resolve | No relief; weight claim denied; jury credibility findings affirmed |
| Whether Lofton’s life-without-parole sentence for juvenile murder complies with Miller retroactively | Lofton contends Miller applies retroactively to require resentencing | Commonwealth concedes Miller applies and requires resentencing | Lofton entitled to resentencing; remanded for Miller-compliant sentencing |
Key Cases Cited
- Commonwealth v. Champney, 832 A.2d 403 (Pa. 2003) (weight versus sufficiency framework; credibility determinations for weight claims)
- Commonwealth v. Diggs, 949 A.2d 873 (Pa. 2008) (weight claims review; least palatable ruling)
- Commonwealth v. Widmer, 744 A.2d 745 (Pa. 2000) (trial court abuse standard in weight-of-the-evidence review)
- Commonwealth v. Priest, 18 A.3d 1235 (Pa. Super. 2011) (preservation of weight claims; waiver considerations)
- Commonwealth v. Karkaria, 625 A.2d 1167 (Pa. 1993) (extreme unreliability of witness testimony; sufficiency rebuttal)
- Commonwealth v. Farquharson, 354 A.2d 545 (Pa. 1976) (prior statements admissible; indicium of reliability; weight considerations)
- Commonwealth v. Brown, 52 A.3d 1139 (Pa. 2012) (distinguishing weight versus sufficiency and prior inconsistent statements)
- Commonwealth v. Cabeza, 469 A.2d 146 (Pa. 1983) (retroactivity of new appellate rules on direct appeal)
- Commonwealth v. McCormick, 519 A.2d 442 (Pa. 1986) (retroactivity approaches in Pennsylvania)
- Griffith v. Kentucky, 479 U.S. 314 (U.S. 1987) (retroactivity of new federal constitutional rules on direct review)
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory life without parole for juveniles unconstitutional; directs re-sentencing consideration)