Com. v. Anderson, J.

CourtSuperior Court of Pennsylvania
DecidedMarch 18, 2025
Docket1538 EDA 2024
StatusUnpublished

This text of Com. v. Anderson, J. (Com. v. Anderson, J.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Com. v. Anderson, J., (Pa. Ct. App. 2025).

Opinion

J-S05021-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : JAHJUAN ANDERSON : : Appellant : No. 1538 EDA 2024

Appeal from the Judgment of Sentence Entered February 2, 2024 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0002531-2019

BEFORE: BOWES, J., MURRAY, J., and STEVENS, P.J.E.*

MEMORANDUM BY MURRAY, J.: FILED MARCH 18, 2025

Jahjuan Anderson (Appellant) appeals from the judgment of sentence

entered following his convictions of one count each of attempted murder,

possessing an instrument of crime (PIC), aggravated assault, person not to

possess firearms, and carrying a firearm on a public street in Philadelphia. 1

After careful review, we affirm.

The trial court summarized the facts underlying the instant appeal:

On May 23, 2018, Robert Bennett [(Mr. Bennett)] was walking with his niece on the 5800 block of Belmar Street in Philadelphia. [N.T.,] 9/12/23[,] at 56-57, 78. Mr. Bennett, who was 20 years old at the time, had recently moved into his sister’s home[,] together with his girlfriend, Jessica Ford [(Ms. Ford)], on the same 5800 block of Belmar Street. Id. at 56. While walking, Mr. ____________________________________________

* Former Justice specially assigned to the Superior Court.

1 See 18 Pa.C.S.A. §§ 901(a) (2502(a)), 907(a), 2702(a)(1), 6105(a)(1), 6106(a)(1), 6108. J-S05021-25

Bennett attempted to throw a plastic water bottle into the recycling bin outside a house at 5839 Belmar Street, which was down the block from his sister’s home. Id. at 57, 147; Commonwealth Exhibit C-20 (“C-20”). The bottle missed the bin and landed on the home’s front porch. [Id.] at 57. Mr. Bennett went to retrieve the bottle from the porch, and in doing so, inadvertently knocked over a three-foot tall brick wall that was on the property. Id. at 52, 57.

The owner of the house, Annie Anderson [(Ms. Anderson)], came outside and became angry with Mr. Bennett for knocking over the wall. Id. at 53, 57, 65-66. Ms. Anderson told Mr. Bennett that she wanted him to fix the wall. Id. at 65-66. Mr. Bennett responded that he did not have the funds to fix the wall but thought that he and his father could fix it together. Id. After a few minutes, Mr. Bennett’s father arrived, and he continued the conversation with Ms. Anderson. Id. at 66-67. Mr. Bennett’s father assured Ms. Anderson that they would figure something out with regard to the wall. Id. at 66.

Trial Court Opinion, 7/30/23, at 3-4.

In the afternoon of June 6, 2018, Appellant and another man, whom

Appellant identified as his now-deceased brother, appeared at the home of

Mr. Bennett’s sister. Appellant identified himself as Ms. Anderson’s son.

Appellant and Mr. Bennett spoke on the front porch for between five and seven

minutes, at which time Appellant insisted that Mr. Bennett fix the wall. During

this time, the other man, who was wearing sunglasses, remained silent.

Mr. Bennett agreed to walk with the two men to Ms. Anderson’s home.

While doing so, Mr. Bennett texted his father. However, as Mr. Bennett looked

at his phone, Appellant shot Mr. Bennett multiple times. Appellant continued

firing his weapon even as Mr. Bennett pleaded with Appellant to stop. Mr.

Bennett sustained ten gunshot wounds as a result of the incident.

-2- J-S05021-25

Mr. Bennett initially told police he could not identify his assailant, but

later identified Appellant as the shooter. Following an investigation, police

arrested Appellant. On September 14, 2024, a jury convicted Appellant of the

above-described charges. Thereafter, on February 2, 2024, the trial court

sentenced Appellant to an aggregate 18-36 years in prison, followed by one

year of probation. Appellant filed a post-sentence motion on February 8,

2024. While that motion was pending, Appellant filed a pro se notice of

appeal. This Court quashed Appellant’s appeal as interlocutory.

Commonwealth v. Anderson, No. 887 EDA 2024 (Pa. Super. filed Apr. 19,

2024) (order). The trial court denied Appellant’s post-sentence motion on

May 28, 2024. Thereafter, Appellant filed the instant timely appeal. Appellant

and the trial court have complied with Pa.R.A.P. 1925.

Appellant presents the following issues for our review:

I. Was the evidence introduced at trial[,] and all reasonable inferences derived from the evidentiary record, viewed in the light most favorable to the Commonwealth as verdict winner, insufficient to establish attempted murder, aggravated assault, and related firearms charges [with Appellant] as an accomplice?

II. Was the jury verdict that Appellant was guilty of criminal attempted murder, aggravated assault[,] and related firearms charges against the weight of the evidence?

Appellant’s Brief at 7.

Appellant first challenges the sufficiency of the evidence underlying his

convictions. In particular, Appellant challenges his purported accomplice

liability as to all charges, arguing he was merely present at the scene of the

-3- J-S05021-25

shooting. Id. at 17. Appellant points out the prosecution’s trial argument

that Appellant “was an accomplice because he went to [Mr.] Bennett’s house

with his [now-deceased] brother.” Id. Appellant argues that, based on the

prosecutor’s argument and the jury’s questions during deliberations, “the jury

had found Appellant guilty because … he acted as an accomplice.” Id. at 19.

Appellant points out that in one jury inquiry, the jury “want[ed] to confirm

that the liability of conduct of another person clause can be applied to all …

charges.” Id. at 20 (quoting N.T., 9/14/23, at 5). According to Appellant,

“there was insufficient evidence of record to establish that Appellant acted as

an accomplice as to any of the charges.” Id. at 21.

Appellant further asserts,

[t]here was no evidence presented by the Commonwealth that [] Appellant solicited, commanded, encouraged or requested his brother to shoot the victim. Nor was there any evidence presented that Appellant somehow aided, agreed to aid[,] or attempted to aid his brother in planning or committing the crime.

Id.

Appellant also directs our attention to the testimony of Ms. Ford, who

described one of the two men, the one wearing sunglasses, as having a bigger

build. Id. Appellant points out evidence that he had a larger build than his

brother. Id. at 22. Appellant further points to Mr. Bennett’s testimony that

the shooter was not wearing sunglasses. Id. According to Appellant, “in

order to apply accomplice liability to [] Appellant, the jury must have found

that Appellant was the brother wearing sunglasses.” Id. Challenging his

-4- J-S05021-25

accomplice liability, Appellant argues “[t]here is no evidence the brother

wearing sunglasses even knew that his brother was going to pull a gun and

fire it.” Id. at 23. Appellant asserts there is no evidence that he discussed

or instructed his brother to shoot the victim, or that he supplied the firearm

to his brother. Id. Appellant argues,

[i]n that Appellant was in all likelihood found guilty of all charges based on his being his [brother’s] accomplice, and the lack of any evidence of record to support that finding, the guilty verdicts simply cannot stand. It violates his constitutional right to a fair trial and due process of law under the 14 th Amendment.

Our standard for reviewing a challenge to the sufficiency of the evidence

is well established:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Commonwealth v. Andrews
768 A.2d 309 (Supreme Court of Pennsylvania, 2001)
Commonwealth v. Jackson
955 A.2d 441 (Superior Court of Pennsylvania, 2008)
Commonwealth v. Heidler
741 A.2d 213 (Superior Court of Pennsylvania, 1999)
Commonwealth v. Moore
937 A.2d 1062 (Supreme Court of Pennsylvania, 2007)
Commonwealth, Aplt v. Gross, E.
101 A.3d 28 (Supreme Court of Pennsylvania, 2014)
Commonwealth v. Talbert
129 A.3d 536 (Superior Court of Pennsylvania, 2015)
Commonwealth v. Gause
164 A.3d 532 (Superior Court of Pennsylvania, 2017)
Commonwealth v. Izurieta
171 A.3d 803 (Superior Court of Pennsylvania, 2017)
Commonwealth v. Santos
176 A.3d 877 (Superior Court of Pennsylvania, 2017)
Commonwealth v. Predmore
199 A.3d 925 (Superior Court of Pennsylvania, 2018)
Commonwealth v. Young
692 A.2d 1112 (Superior Court of Pennsylvania, 1997)
Commonwealth v. Fortune
68 A.3d 980 (Superior Court of Pennsylvania, 2013)
Com. v. Rogers, E.
2021 Pa. Super. 169 (Superior Court of Pennsylvania, 2021)
Com. v. Juray, R., Jr.
2022 Pa. Super. 83 (Superior Court of Pennsylvania, 2022)
Com. v. Spence, O.
2023 Pa. Super. 22 (Superior Court of Pennsylvania, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Com. v. Anderson, J., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-anderson-j-pasuperct-2025.