Com. v. Bettis, R.

2025 Pa. Super. 244
CourtSuperior Court of Pennsylvania
DecidedOctober 28, 2025
Docket1188 WDA 2024
StatusPublished

This text of 2025 Pa. Super. 244 (Com. v. Bettis, R.) 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. Bettis, R., 2025 Pa. Super. 244 (Pa. Ct. App. 2025).

Opinion

J-A19011-25

2025 PA Super 244

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : RICHARD M. BETTIS : : Appellant : No. 1188 WDA 2024

Appeal from the Judgment of Sentence Entered July 22, 2024 In the Court of Common Pleas of Westmoreland County Criminal Division at No(s): CP-65-CR-0000137-2022

BEFORE: BOWES, J., STABILE, J., and BENDER, P.J.E.

OPINION BY BENDER, P.J.E.: FILED: October 28, 2025

Richard M. Bettis (Appellant) appeals from the judgment of sentence of

one year of probation, imposed following his convictions for resisting arrest,

defiant trespass, disorderly conduct, and harassment.1 He challenges the

authority of the school police officers to arrest him, the sufficiency of the

evidence for his convictions, and also claims that the guilty verdicts are

contrary to the weight of the evidence provided. We affirm.2

____________________________________________

1 18 Pa.C.S. §§ 5104, 3503(b)(1)(i), 5503(a)(1), and 2709(a)(1), respectively.

2 On August 4, 2025, the day before oral argument was scheduled in this appeal, defense counsel filed an application to move oral argument to the expedited list. As the motion was filed the day before arguments, the panel did not have the time to issue a formal order granting the request. Nonetheless, this case was argued on an expedited basis. We therefore deny the outstanding defense motion as moot. J-A19011-25

Charges in this case surround Appellant’s actions on September 10,

2021. The trial court set forth the facts of this incident as follows:

Hempfield Area School District Police Officer Shannon Binda testified that, on September 10, 2021, he was checking people in at the high school front desk, along with Chief [Len] Lander. A female student was sitting next to the front desk at that time. [Appellant] came to the front doors and was “buzzed in” by the officers. [Appellant] wanted to speak to the principal and deliver paperwork to make the school administration aware of the change in masking requirements, stating that the mask requirement was unconstitutional. [Appellant] was asked to put on a mask, but refused. [Appellant] stated that he had an underlying medical condition. [Appellant] conceded that the officers offered to step outside with him to talk about it. [Appellant] refused to leave the building. [Appellant] did not have an appointment so Officer Binda denied him entry to the school and offered to pass along the information he had for the principal. [Appellant] stated that he had a right to be there and the officers could not tell him otherwise. He said that he spoke to an attorney and he had a right to be inside the school because he paid taxes. Officer Binda told [Appellant] that he would have to leave the school and he refused, demanding that he speak to a principal. [Appellant] stated that he “was not leaving until he spoke to a principal.” [Appellant] began to get very agitated. The vestibule at the high school is not secure and has direct access to the rest of the building. The main hallway where students were walking by was just 30 feet away. Officers viewed [Appellant] as a possible safety threat.

Officer Binda got up and began to escort [Appellant] out of the school, telling him multiple times that he would have to leave the premises. [Appellant] argued and refused to comply. It was clear that [Appellant] was not going to leave the building despite numerous directives to do so. At one point, [Appellant] stated that he would call the [Pennsylvania] State Police and the officers informed him that he would need to do that outside the building.

Officer Blinda then attempted to arrest [Appellant] for defiant trespassing when a scuffle ensued. Specifically, Officer Binda attempted to pull [Appellant] out the door while [Appellant] pushed back and attempted to remain inside. [Appellant] attempted to get back into the school and began wrestling with

-2- J-A19011-25

the two officers. Officer Binda and Chief Lander had to take [Appellant] to the ground outside the building. [Appellant] pushed the officers’ hands away while scuffling with the officers. At one point, Chief Lander noted that [Appellant] “appeared to be bringing his fist back.” [Appellant] was handcuffed and informed that he was under arrest at that time. Officer Binda suffered a laceration to his arm while wrestling with [Appellant].

On March 25, 2024, [after a non-jury trial,] the court entered a verdict finding [Appellant] “Guilty” of counts 3, 4, 5, and 6[,] and “Not Guilty” of counts 1 and 2[.][3] [The court] stated its reasoning for the verdict [on the record]. This court sentenced [Appellant] on July 22, 2024, and placed him on one year of probation. [Appellant] filed timely post-sentence motions on July 31, 2024. The Commonwealth filed a response to [the] post- sentence motion on August 23, 2024. A hearing was scheduled for August 27, 2024. Just hours before the hearing, [Appellant] filed a supplemental post-sentence motion raising an additional claim.

Trial Court Opinion (TCO), 8/28/24, at 2-3 (unnumbered; citations omitted;

emphasis in original; some capitalization altered).

Appellant’s post-sentence motion, including the issue raised in the

supplemental motion, was denied on August 28, 2024. He then filed a timely

notice of appeal on September 27, 2024. Pursuant to the trial court’s order,

Appellant filed his concise statement of errors complained of on appeal on

October 21, 2024. In response, the trial court informed this Court that the

reasons for the denial of Appellant’s issues on appeal could be found in the

opinion denying Appellant’s post-sentence motions. Decree Pursuant to Rule

1925(a), 10/24/24. This appeal is now properly before this Court for

disposition.

3 Count 1 charged Appellant with aggravated assault, 18 Pa.C.S. § 2702(a)(3).

Count 2 charged Appellant with simple assault, 18 Pa.C.S. § 2701(a)(1).

-3- J-A19011-25

Appellant puts forth seven issues on appeal, which we reorder for ease

of disposition:

1. Whether the trial court erred by failing to address the lack of legal authority of the arresting officer to arrest Appellant for defiant trespass – an offense graded as at least a misdemeanor of the third degree – when the officer’s authority was limited to summary offenses, thereby rendering the arrest, and consequently the resisting arrest charge, unlawful?

2. Whether the trial court erred in concluding that the evidence was sufficient to sustain Appellant’s conviction for defiant trespass under 18 Pa.C.S. § 3503(b), where Appellant was wrongfully informed that his presence on school property was unlawful and [he] reasonably believed he was permitted to remain on the premises?

3. Whether the trial court erred in concluding that the evidence was sufficient to sustain Appellant’s conviction for resisting arrest under 18 Pa.C.S. § 5104, where the arrest was unlawful, Appellant reasonably believed that he was permitted to remain on school property to deliver paperwork, and the Commonwealth failed to prove that Appellant created a substantial risk of bodily injury or required substantial force to overcome his resistance?

4. Whether the trial court erred in concluding that the evidence was sufficient to sustain Appellant’s conviction for disorderly conduct under 18 Pa.C.S. § 5503(a)(1), where the Commonwealth failed to prove that Appellant engaged in fighting, threatening, or tumultuous behavior with [the] intent to cause public inconvenience, annoyance, or alarm?

5. Whether the trial court erred in concluding that the evidence was sufficient to sustain Appellant’s conviction for harassment under 18 Pa.C.S.

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2025 Pa. Super. 244, Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-bettis-r-pasuperct-2025.