Commonwealth v. Stokes
78 A.3d 644
| Pa. Super. Ct. | 2013Background
- Dec. 26, 2009: After a fight at the Fireside Tavern, Gjon Goods was shot and later died of a chest (.44 caliber) wound; Shaina Miller (wounded in the hand) and two others witnessed the shooting.
- Multiple eyewitnesses (Shaina Miller, Sean Miller, Michelle Canzoneri) identified appellant as the shooter in photo arrays and at trial; Shaina knew appellant before the incident.
- Police arrested appellant at 342 Winton Street (his aunt’s home) and executed a search warrant of his bedroom; they recovered two paper shooting targets (with bullet holes), four loose .32 rounds, an empty box of 9mm ammunition, photographs, and an appointment card in appellant’s name; no firearm or .44-caliber ammunition was recovered.
- Jury convicted appellant of first-degree murder, aggravated assault, and VUFA; acquitted of possessing an instrument of a crime; sentence: life without parole (first-degree murder) plus consecutive 10–20 years for aggravated assault.
- Appellant appealed, arguing (1) insufficiency of evidence, (2) verdict against the weight of the evidence, and (3) erroneous admission of unrelated ammunition/target evidence from his bedroom (motion in limine denied).
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Appellant) | Held |
|---|---|---|---|
| Sufficiency of evidence for first‑degree murder | Eyewitness ID and testimony show appellant fired multiple shots at victim (vital chest wound), supporting specific intent to kill | Commonwealth failed to prove appellant was shooter or had specific intent to kill | Affirmed — evidence (multiple IDs, shot to vital area) was sufficient to prove first‑degree murder |
| Weight of the evidence (motion for new trial) | Eyewitness testimony credible; inconsistencies minor and for jury to resolve | Testimony conflicts (height, clothing, conflicting accounts) render verdict shocking and unreliable | Affirmed — trial court did not abuse discretion; verdict did not shock sense of justice |
| Admissibility of ammunition/targets recovered from 342 Winton St. (motion in limine) | Evidence shows familiarity with guns/aim and is probative of ability/use of firearms | Evidence irrelevant and unfairly prejudicial (different calibers; not linked to crime); suggested other crimes | Court erred in admitting this evidence (unrelated to .44 murder weapon), but error was harmless given overwhelming admissible evidence of guilt |
| Preservation/waiver of evidentiary challenge | Admission was litigated pretrial; ruling final — preserved for appeal | Commonwealth argued waiver because no contemporaneous objection at trial | Issue preserved — motion in limine litigated and ruling definitive; appellate review allowed |
Key Cases Cited
- Commonwealth v. Coon, 695 A.2d 794 (Pa. Super. 1997) (standard for reviewing sufficiency of evidence)
- Commonwealth v. McFadden, 850 A.2d 1290 (Pa. Super. 2004) (elements of first‑degree murder/specific intent discussion)
- Commonwealth v. Hawkins, 701 A.2d 492 (Pa. 1997) (using deadly force on a vital part shows specific intent to kill)
- Commonwealth v. Widmer, 744 A.2d 745 (Pa. 2000) (standard for weight‑of‑the‑evidence review)
- Commonwealth v. Robinson, 721 A.2d 344 (Pa. 1998) (error to admit weapons evidence not linked to the crime)
- Commonwealth v. Owens, 929 A.2d 1187 (Pa. Super. 2007) (standard of review for motion in limine and admissibility of unrelated weapons evidence)
- Commonwealth v. Broaster, 863 A.2d 588 (Pa. Super. 2004) (admission of non‑murder weapon admissible only under particular facts linking it to the crime)