Commonwealth v. Williams
153 A.3d 372
| Pa. Super. Ct. | 2016Background
- Appellant Jack Williams was at Kintock Hall (a contracted halfway house) after the Board issued a warrant for technical parole violations (changing residence without permission, failure to report).
- On December 2, 2014, while at Kintock Hall he was escorted to Temple University Hospital for a medical emergency and left the escort at the hospital without authorization.
- Commonwealth charged Williams with escape under 18 Pa.C.S. § 5121(a). He was tried before a judge, convicted, and sentenced to 11½ to 23 months’ imprisonment on September 30, 2015.
- Williams appealed, arguing (1) insufficient evidence because he was a parolee (and parole supervision is excluded from “official detention”), and (2) after-discovered evidence (a March 3, 2016 Board letter) showing he was on parole and thus not in official detention.
- The trial court and the Superior Court found the record showed Williams was detained at Kintock pending adjudication of parole violations and that leaving constituted escape under § 5121.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Williams) | Held |
|---|---|---|---|
| Whether evidence established "official detention" under § 5121 when Williams left the hospital | Kintock held Williams pending parole-violation adjudication; detainees there are not free to come and go, so removal = escape | Williams was still a parolee (parole not revoked until later), and supervision of parole is excluded from "official detention" | Court: Sufficient evidence of official detention; Maldonado controls — parolees detained for violations are under official detention |
| Whether a March 3, 2016 Board letter is after-discovered evidence warranting remand/new trial | Letter does not change that he was detained pending violation adjudication; conviction stands | Letter shows he was a parolee at the time, so conviction improper | Court: Letter is merely cumulative/corroborative and would not change outcome; petition to remand denied |
Key Cases Cited
- Commonwealth v. Widmer, 744 A.2d 745 (Pa. 2000) (sufficiency-of-the-evidence standard)
- Commonwealth v. Antidormi, 84 A.3d 736 (Pa. Super. 2014) (review principles for appellate sufficiency claims)
- Commonwealth v. Maldonado, 966 A.2d 1144 (Pa. Super. 2009) (parolees detained for alleged parole violations and placed in detention facilities may be in official detention for § 5121 purposes)
- Commonwealth v. Castro, 93 A.3d 818 (Pa. 2014) (Rule 720 timing for after-discovered evidence motions)
- Commonwealth v. Rivera, 939 A.2d 355 (Pa. Super. 2007) (four-prong test for after-discovered evidence)