Commonwealth v. Roche, 153 A.3d 1063

On April 21, 2014, James Edward Roche and Holly Crawford shot and killed Ronald Evans (73) and his son Jeffrey Evans (43) in the Evans home; ten shots were fired and forensic testimony established wounds independently sufficient to cause death.
Roche and Crawford were later found in the woods; police recovered firearms, alcohol, and other items; Roche made oral and written statements to police on April 23, 2014 admitting to the shootings.
Roche was tried by jury (November 2015), convicted of two counts of first-degree murder and related conspiracy counts, and sentenced on January 8, 2016 to consecutive life terms plus lengthy sentences for conspiracy.
Pretrial, Roche moved to suppress his April 23 statement asserting intoxication and impaired capacity; the suppression court held a hearing and denied the motion after crediting Corporal King’s testimony that Roche knowingly and voluntarily waived Miranda rights.
On appeal Roche raised (1) suppression ruling and (2) claim that evidence was insufficient to support convictions; the Superior Court affirmed, rejecting the suppression challenge and finding the sufficiency challenge waived (and alternatively without merit).

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Motion to suppress April 23 statement	Commonwealth: statement was knowingly, intelligently, voluntarily waived; admissible	Roche: severe intoxication, exhaustion, and impaired cognition rendered waiver involuntary	Denied — suppression court credited officer testimony; waiver valid and appeal rejected
2. Sufficiency of evidence for 1st-degree murder and conspiracy	Commonwealth: circumstantial and direct evidence, including Roche’s admissions, support premeditation and agreement with Crawford	Roche: intoxication and his testimony show lack of plan/intent and no agreement to kill	Waived for procedural defects in Rule 1925(b) and inadequate briefing; alternative holding — evidence sufficient

Galvin v. Commonwealth, 985 A.2d 783 (Pa. 2009) (standard of review for suppression rulings)
Gallagher v. Commonwealth, 896 A.2d 583 (Pa. Super. 2006) (credibility determinations are for the suppression court)
In re L.J., 79 A.3d 1073 (Pa. 2013) (scope of review limited to suppression hearing record)
Doughty v. Commonwealth, 126 A.3d 951 (Pa. 2015) (circumstantial evidence can sustain conviction)
Hitcho v. Commonwealth, 123 A.3d 731 (Pa. 2015) (premeditation can be formed in a brief period)
Diamond v. Commonwealth, 83 A.3d 119 (Pa. 2013) (definition of first-degree murder as intentional killing)
McCall v. Commonwealth, 911 A.2d 992 (Pa. Super. 2006) (elements of criminal conspiracy)
Tyack v. Commonwealth, 128 A.3d 254 (Pa. Super. 2015) (Rule 1925(b) waiver principles)
Williams v. Commonwealth, 959 A.2d 1252 (Pa. Super. 2008) (Rule 1925(b) specificity required to preserve sufficiency claims)
Ellis v. Commonwealth, 700 A.2d 948 (Pa. Super. 1997) (failure to develop appellate argument results in waiver)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda warning/waiver framework)