Commonwealth v. Williams
176 A.3d 298
Pa. Super. Ct.2017Background
- On June 1, 2014 Rashawn J. Williams shot and killed Aaron Lowry outside a Williamsport hookah lounge; Williams fled to High Point, NC, was captured June 6 and treated at High Point Regional Hospital.
- Williams was extradited to Pennsylvania and tried by jury on charges including first-degree murder, aggravated assault, illegal possession of a firearm, and flight to avoid apprehension.
- At trial Williams admitted pulling a gun from his pocket, pointing it at the victim and firing; the bullet struck the victim’s chest and punctured a lung, causing death.
- Defense theory: self-defense (victim and others attacked Williams; victim had a knife). Prosecution relied on witness testimony that victim did not brandish a knife and on phone calls, physical evidence (knife in victim’s pocket), and Williams’ inconsistent statements.
- Trial court admitted certified NC medical records (obtained pursuant to court orders), excluded portions of defense expert Dr. Vey’s opinion as speculative, excluded a remote prior conviction of the victim, and admitted several recorded phone calls and rebuttal evidence.
- Jury convicted on all counts; trial court sentenced Williams to life without parole plus concurrent terms. Superior Court affirmed.
Issues
| Issue | Williams’ Argument | Commonwealth/Trial Court Argument | Held |
|---|---|---|---|
| Sufficiency—specific intent for 1st‑degree murder | No proof of specific intent to kill; victim was initial aggressor so shooting was reactive | Jury may infer intent from use of a deadly weapon on a vital part; Williams admitted pointing and firing a gun at close range | Affirmed—sufficient evidence to infer specific intent from use of firearm on victim’s chest |
| Sufficiency—malice for aggravated assault | Evidence did not show requisite malice | Malice may be inferred from use of a deadly weapon on a vital part of the body | Affirmed—malice inference supports aggravated assault verdict |
| Self‑defense (including duty to retreat/Stand‑your‑ground) | Victim and others jumped Williams; he lacked safe retreat; victim displayed knife | Evidence disputed knife display; Williams illegally possessed firearm so cannot claim stand‑your‑ground and had duty to retreat; Commonwealth disproved self‑defense beyond reasonable doubt | Affirmed—self‑defense not proven; illegal gun possession and lack of proof of knife defeat claim |
| Weight of the evidence (new trial) | Verdict shocks the conscience; defense witness testimony more credible | Trial court found jury credibility choices reasonable and verdict not against justice | Affirmed—trial court did not abuse discretion in denying new trial |
| Heat‑of‑passion voluntary manslaughter instruction | Requested because victim was initial aggressor and there was no cooling off | No evidence Williams acted under sudden, intense passion; defense centered on self‑defense, not provocation/heat of passion | Affirmed—court did not err in refusing heat‑of‑passion instruction |
| Suppression of NC medical records (HIPAA) | Records obtained in violation of HIPAA; no notice/opportunity to be heard; suppression required | Commonwealth obtained court orders; HIPAA does not prohibit disclosure to prosecutors pursuant to court order and law‑enforcement exception; HIPAA provides no suppression remedy | Affirmed—records lawfully obtained under law‑enforcement/court‑order exception; suppression not warranted |
| Exclusion/admission of evidence (Dr. Vey, victim’s prior conviction, phone calls, rebuttal items) | Exclude rulings deprived Williams of impeachment/defense (Dr. Vey’s opinion, victim prior conviction, surrebuttal testimony on witness uncooperativeness); exclude certain Commonwealth evidence as hearsay/irrelevant | Court excluded speculative expert opinion as impermissibly indefinite; victim’s old conviction too remote and dissimilar; surrebuttal proffer speculative and irrelevant; Commonwealth evidence admissible for impeachment, consciousness of guilt, and as non‑hearsay or excluded‑as‑non‑offered‑for‑truth | Affirmed—trial court acted within discretion on evidentiary rulings; any error harmless |
Key Cases Cited
- Sanchez v. Commonwealth, 36 A.3d 24 (Pa. 2011) (use of deadly weapon on vital part supports inference of intent to kill)
- Ballard v. Commonwealth, 80 A.3d 380 (Pa. 2013) (elements required for murder convictions)
- Washington v. Commonwealth, 927 A.2d 586 (Pa. 2007) (intent inference focuses on use of weapon on vital part, not precise aiming)
- Hitcho v. Commonwealth, 123 A.3d 731 (Pa. 2015) (malice inference from deadly‑weapon use)
- Mouzon v. Commonwealth, 53 A.3d 738 (Pa. 2012) (limits on admitting victim’s prior convictions for self‑defense impeachment: similarity and remoteness)
- Mason v. Commonwealth, 130 A.3d 601 (Pa. 2015) (heat‑of‑passion standards and requirements for instruction)
- Woodard v. Commonwealth, 129 A.3d 480 (Pa. 2015) (appellate waiver where arguments are undeveloped)
- Chmiel v. Commonwealth, 889 A.2d 501 (Pa. 2005) (harmless‑error standard for evidentiary rulings)