Com. v. Best, S.

Superior Court of Pennsylvania·Decided July 28, 2026·No. 1574 WDA 2024·Unpublished·Nichols

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37 COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

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v. :

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STEVEN DANIEL BEST, JR. :

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Appellant : No. 1574 WDA 2024 Appeal from the Judgment of Sentence Entered December 12, 2024

In the Court of Common Pleas of Westmoreland County Criminal Division at No(s): CP-65-CR-0000639-2023

BEFORE: BOWES, J., NICHOLS, J., and KING, J. MEMORANDUM BY NICHOLS, J.: FILED: JULY 28, 2026 Appellant Steven Daniel Best, Jr., appeals from the judgment of sentence imposed after he was convicted of kidnapping and robbery1 following a jury trial. Appellant claims that the trial court erred by allowing the admission of text messages at trial. We affirm.

The trial court summarized the facts and procedure below as follows:

[Appellant] was charged with kidnapping, robbery, and simple assault due to an incident that occurred on December 18, 2022, in New Kensington, Westmoreland County.

1 See 18 Pa.C.S. §§ 2901(a)(3) and 3701(a)(1)(v), respectively.

* * *

[Prior to trial, Appellant] indicated that he intended to file a motion in limine to exclude text messages that were sent after the incident to Angela Gregory [(Victim)]. [Appellant] did not make a specific objection to certain messages but argued generally that all of the messages should be excluded.

Subsequently, [Appellant] provided a motion in limine to the court. In that motion, [Appellant] asked [the trial court] to preclude all testimony or evidence involving [the text] messages.

. . . He claimed that the messages would be more prejudicial than probative, and they are not relevant to whether he committed the alleged acts. Furthermore, he argued that the messages are not relevant to show consciousness of guilt because they were sent prior to any charges being filed, they would be admitted in violation of the corpus delicti rule, and they would confuse the jury. [Appellant] again provided a general objection to all of the messages being admitted and did not argue why any specific messages should be excluded.

[The trial court] reviewed and weighed all the text messages that the Commonwealth intended to introduce and [indicated that some messages appeared admissible while two of the messages did not “seem to have much probative value and lots of prejudicial value.” See N.T., 9/30/24, at 3-6.]

[Appellant] argued that [he] could not be consciously guilty of anything because charges were not yet filed against him. The Commonwealth responded that several messages were sent after charges were filed against [Appellant]. [The trial court] ultimately denied [Appellant’s] motion in limine.

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[Appellant] additionally argued that the messages should not be admissible under the best evidence rule because the Commonwealth did not establish the exact time that the messages were sent, other than the Victim stating approximately when they were sent. Id. at 79. [The trial court] denied [Appellant’s] best evidence rule claim[. See id. at 180, 186-89.]

Trial Ct. Op., 2/14/25, at 1-5 (some footnotes omitted and some formatting altered).

A jury trial was held from September 30, 2024 to October 2, 2024. See id. at 8. During the trial, the Victim testified that she and Appellant had a romantic relationship that commenced in October of 2022. See N.T., 10/1/25, at 204-06. On December 17, 2022, the Victim drove to Appellant’s residence and stayed overnight with Appellant and then, on the morning of December 18, 2022, when the Victim attempted to leave the residence Appellant physically prevented her from leaving. See id. at 213-14, 217. Specifically, the Victim testified that at one point Appellant shut the front door on her arm, causing her pain and trapping her inside the residence; that she sought help from Appellant’s roommate but the roommate refused to help her; that Appellant forced the Victim into the basement of his residence; that when the Victim threatened to call the police that Appellant took her phone and withheld it from her for two hours; and that Appellant physically prevented the Victim from leaving his residence for a period of nearly three hours. See id. at 214, 218-20, 222, 224-28.

The Victim also testified that, after Appellant finally allowed her to leave his residence on December 18, 2022, Appellant began barraging her with phone calls, text messages, and Facebook messages. See Trial Ct. Op., at 2/14/25, at 14; see also N.T., 10/1/25, at 234-35. She testified that after she blocked Appellant’s number he used a new number to contact her. See Trial Ct. Op., at 2/14/25, at 14. Screenshots of the text messages and audio

recordings of the voice messages referenced by the Victim in this testimony, dated December 18, 2022 to January 3, 2023, were entered as evidence by the Commonwealth. See id.; see also Cmwlth. Exs. 3-12. To establish the authenticity of Appellant’s text messages proffered by the Commonwealth as evidence, the Victim testified that she had taken screenshots of the messages from her personal phone and that she had not tampered with or omitted any messages within the feed of messages before providing the screenshots to the police. See N.T., 10/1/24, at 97-118, 135-162.

The jury found Appellant guilty of kidnapping and robbery but acquitted Appellant of simple assault. See Trial Ct. Op., 2/14/25, at 8. Appellant was sentenced to an aggregate sentence of five to ten years of incarceration followed by twelve months of re-entry supervision. See id.

Appellant filed a timely notice of appeal and both Appellant and the trial court complied with Pa.R.A.P. 1925.

On appeal, Appellant raises the following claims:

1. Whether the court committed reversible error in denying Appellant’s motion in limine and finding that prejudicial text messages were relevant for consciousness of guilt purposes despite their prejudice outweighing their probative value.

2. Whether the court committed reversible error by allowing the text messages to be admitted in a format th[at] violated the best evidence rule.

Appellant’s Brief at 7 (some formatting altered).

In support of his prejudice claim, Appellant notes that the trial court admitted “approximately 700 text messages and other interactions” for the

purpose of establishing Appellant’s consciousness of guilt. Id. at 12. The trial court only excluded two of the proffered messages on the basis that they had more prejudicial than probative value. Id. Appellant contends that the Commonwealth only cited to two of the 700 admitted messages as evidence of consciousness of guilt at trial and argues that the “practical use of [the messages] was for an impermissible reason,” rather than for consciousness of guilt. Id. at 14. Appellant argues that the trial court erred in concluding that “‘the volume of the text messages, coupled with their nature and tone[,] were indicative of Appellant’s consciousness of guilt.’” Id. at 16. Appellant contends that the quantity of messages admitted, that is, the sheer volume of the messages, is what created the prejudice. Id. at 17.

In support of his best evidence claim, Appellant argues that the Commonwealth should have offered either the Victim’s phone itself or a forensic analysis of the phone, not just screenshots of messages. See id. at 18. Appellant contends that the screenshots may have omitted messages and, in that case, would not be accurate reproductions of the original messages. See id. Ultimately, Appellant argues that the majority of the messages should have been excluded both because the best evidence was “so readily available” to the Commonwealth and because the large volume of messages “outsize[d] any other evidence presented in the case.” Id. at 19.

Our Supreme Court has previously stated the following:

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Com. v. Best, S., (Pa. Ct. App. 2026).

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