Commonwealth v. Muhammad, R., Aplt.
109 MAP 2023
| Pa. | May 30, 2025Background
- Rasheed Muhammad was charged with various crimes, including two firearms offenses: "persons not to possess a firearm" under 18 Pa.C.S. § 6105 and "carrying a firearm without a license" under 18 Pa.C.S. § 6106.
- To avoid prejudicing the jury with Muhammad’s prior felony (which is relevant only to § 6105), the court used a special procedure involving a special interrogatory on possession before proceeding to full jury instruction on § 6105.
- The jury found Muhammad guilty of carrying a firearm without a license, but answered “no” to the interrogatory asking if he possessed the firearm.
- As a result, Muhammad was acquitted of the persons not to possess charge without further jury instruction.
- The trial and appellate courts were faced with whether the inconsistency between the general verdict (conviction) and the special interrogatory (no possession) affected the validity of the conviction.
- The Supreme Court opinion addresses the applicability of the inconsistent verdicts doctrine to conflicts between a general verdict and a special interrogatory in a criminal case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Consistency between general verdict and interrogatory | Responds that the two verdicts are inconsistent | Argues verdicts are not inconsistent | The conviction and interrogatory are inconsistent |
| Effect of inconsistency on conviction | Inconsistency undermines conviction | Inconsistency does not invalidate conviction | Inconsistent verdicts doctrine applies; conviction stands |
| Validity of using special interrogatories in criminal cases | Interrogatory reflects true facts | Interrogatory not a valid basis to disturb verdict | Special interrogatories did not justify vacating verdict |
| Precedent value of Commonwealth v. Magliocco | Cited as basis to vacate convictions for inconsistency | Should be overruled as incompatible with precedent | Magliocco wrongly decided and overruled |
Key Cases Cited
- Commonwealth v. Carter, 282 A.2d 375 (Pa. 1971) (jury may render inconsistent verdicts in criminal cases)
- United States v. Powell, 469 U.S. 57 (1984) (inconsistent criminal verdicts do not warrant setting aside convictions)
- Commonwealth v. Miller, 35 A.3d 1206 (Pa. 2012) (review of criminal conviction is for sufficiency of the evidence regardless of inconsistency)
- Commonwealth v. Magliocco, 883 A.2d 479 (Pa. 2005) (case overruled on doctrine for compound offenses and inconsistent verdicts)
- Commonwealth v. Peters, 218 A.3d 1206 (Pa. 2019) (defining possession and control for firearms offenses)
- Commonwealth v. Moore, 103 A.3d 1240 (Pa. 2014) (limiting Magliocco and reaffirming the inconsistent verdicts rule)