Com. v. Brown-Camp, B.

Superior Court of Pennsylvania·Decided January 23, 2026·No. 977 EDA 2025·Unpublished·Bowes

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

Appellant :

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v. :

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BRYAN BROWN-CAMP : No. 977 EDA 2025

Appeal from the PCRA Order Entered April 1, 2025 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0003503-2015

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

Appellant :

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:

v. :

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MAURICE SMITH : No. 976 EDA 2025

Appeal from the PCRA Order Entered April 1, 2025 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0003502-2015

BEFORE: BOWES, J., BECK, J., and FORD ELLIOTT, P.J.E.* MEMORANDUM BY BOWES, J.: FILED JANUARY 23, 2026 The Commonwealth appeals from the orders granting the petitions filed by co-defendants Bryan Brown-Camp and Maurice Smith, pursuant to the Post Conviction Relief Act (“PCRA”). For the reasons discussed infra, we reverse

the orders granting relief.

* Retired Senior Judge assigned to the Superior Court.

This homicide has a long history in this Court. 1 In 2017, Smith and Brown-Camp were convicted by a jury of third-degree murder and conspiracy to commit robbery for their involvement in the shooting death of Tevan Patrick. According to the Commonwealth, on April 22, 2013, the co- defendants had “lured the victim into their car to ostensibly commit a robbery, but [ended up] kill[ing] him.” Commonwealth v. Brown-Camp (“Brown- Camp I”), 209 A.3d 525, 2019 WL 310813, at *1 (Pa.Super. 2019) (unpublished memorandum).

Since their jury trial, we have had multiple occasions to address the propriety of their convictions. In doing so, we supplied the following background and outline of the evidence produced at trial:

On April 25, 2013, the body of [Mr.] Patrick . . . was found inside an abandoned property in Philadelphia. [Mr. Patrick] had been shot nine times at close range. After an investigation, the Commonwealth charged [Smith and Brown-Camp], with murder, conspiracy to commit murder, robbery, conspiracy to commit robbery, possession of a firearm prohibited, firearms not to be carried without a license, carrying a firearm in Philadelphia, and possession of an instrument of crime. A jury trial occurred from February 22, 2017 to March 2, 2017.

....

1 Indeed, this author alone has already drafted three non-precedential decisions in prior appeals from orders disposing of the same PCRA petitions at issue in the matters sub judice. See Commonwealth v. Brown-Camp, 336 A.3d 973, 2025 WL 817162 (Pa.Super. 2025) (non-precedential decision); Commonwealth v. Brown-Camp, 287 A.3d 901, 2022 WL 16545564 (Pa.Super. 2022) (non-precedential decision); Commonwealth v. Smith, 287 A.3d 849, 2022 WL 6906967 (Pa.Super. 2022) (non-precedential decision).

The circumstantial evidence presented in this case weaves together a tale of the actions of [Smith] and Brown-Camp throughout the day on April 22, 2013. The day began with [Mr.

Patrick] sending a text message to Janeicia Jackson, Brown-

Camp’s girlfriend, requesting Brown-Camp’s new cell phone number. Sometime after Jackson provided the number, Brown-

Camp called [Smith] and asked [Smith] to pick him up. [Smith]

and his girlfriend, Jackie Brown, picked up Brown-Camp in her four[-]door silver Hyundai. [Smith] and Brown-Camp dropped Brown off at work, at approximately 3:00 p.m., and borrowed her car. Reginald Tyler, [Mr. Patrick’s] childhood friend, saw [Mr.

Patrick] get into a silver[,] four[-]door car at the Citgo Station in Delaware. The phones of Brown-Camp and [Mr. Patrick] were both utilizing a cell phone tower near the Citgo Station at 7:26 p.m. and were in contact with one another at that time. The phones were geographically tracked to Southwest Philadelphia, along with [Smith’s] cell phone. All three phones were utilizing cell towers that covered that site where [Mr. Patrick’s] body was recovered. The property where [Mr. Patrick’s] body was recovered was an abandoned property where [Smith’s] cousin stayed sometimes. [Mr. Patrick’s] cell phone went off-line at approximately 10:00 p.m., somewhere over the Schuylkill River, within a half-hour of being geographically located near Southwest Philadelphia with the phones of [Smith] and Brown-Camp. When the phone went offline, it was utilizing cell towers in the same area as [Smith’s] phone, on the Schuylkill Expressway. Finally, [Smith]

is seen by Jackson arriving in Brown’s four[-]door silver car, a little after 10:00 p.m., at [Smith’s] home, located at 3830 Parish Street (which is a short distance from the Schuylkill Expressway).

[Mr. Patrick] is last seen at the Citgo Station in Delaware on April 22, 2013. The last time he is heard from is close to 9:30 p.m.

that evening when he states he is with Brown-Camp.

Commonwealth v. Smith (“Smith I”), 2019 WL 473575, at *1-2 (Pa.Super. 2019) (unpublished memorandum) (cleaned up).

Specifically, he sent two text messages shortly before his phone went offline, which referred to Brown-Camp by his known nickname of “B-Y.” First, at 9:22 p.m., Mr. Patrick texted a female friend that “if some fishy shit happen

I was wit B-Y.” Id. He also texted Reginald Tyler that “if anything fishy happened to me, B-Y did it.” Commonwealth v. Brown-Camp (“Brown- Camp II”), 287 A.3d 901, 2022 WL 16545564, at *1 (Pa.Super. 2022) (non- precedential decision) (cleaned up). Importantly, “[a]round that time, the cell phones of [Mr. Patrick], [Smith], and Brown-Camp were all traced in the area of the abandoned house where [Mr. Patrick’s] body was found.” Smith I, 2019 WL 473575, at *2 (cleaned up).

Within the following week, Brown-Camp sought advice from his cousin, Melissa Palmer, about potential questions that homicide detectives might ask him because her ex-boyfriend had previously been investigated for and convicted of murder.2 Brown-Camp explained that he had set up Mr. Patrick and was being blamed for his death based upon text messages Mr. Patrick sent. He admitted that he was present during the shooting, but was not the one who shot Mr. Patrick. See N.T. Jury Trial, 2/24/17 (morning), at 69.3 Meanwhile, Smith told Terry Kearney and William Cummings “that he

2 At the subsequent trial, the Commonwealth frequently refreshed Ms. Palmer’s recollection during her direct examination with her prior statement to police.

3 The certified record contains two transcripts for February 24, 2017, both of

which are labeled Volume I. For ease of reference, we named the volume containing the full testimony of Officer Raymond Andrejczak and Ms. Palmer and the direct examination of Terry Kearney as the morning volume, and the volume containing the remainder of Mr. Kearney’s testimony as the afternoon. See N.T. Jury Trial, 2/24/17 (afternoon), at 5 (indicating that Mr. Kearney’s cross-examination began at 3:16 p.m.).

committed the murder during the course of a robbery that he and Brown- Camp planned.” Smith, 2019 WL 473575, at *2 (cleaned up).

Eugene Baylor, an individual from the neighborhood who knew the co-

defendants, testified at trial that in the spring of 2013, Smith asked him about serving in the Vietnam War and what it had felt like to kill someone. See N.T. Trial, 2/27/17, at 31. Later, Smith showed Mr. Baylor a .22 caliber shell and said “I did that.” Id. at 32-35. Mr. Baylor stopped Smith before he could say anything else. Although Mr. Baylor admitted to frequent drug use in 2013, which he used to purchase from the co-defendants, and having used heroin the morning he testified, he had provided the same statement to police in June of 2014. He further relayed that Brown-Camp was present for these conversations.

We summarized the pertinent forensic evidence like so:

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Com. v. Brown-Camp, B., (Pa. Ct. App. 2026).

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