Com. v. Dingle, A.

Superior Court of Pennsylvania·Decided February 26, 2026·No. 2455 EDA 2024·Unpublished·Stabile

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

:

v. :

:

:

ANTHONY DINGLE :

:

Appellant : No. 2455 EDA 2024

Appeal from the Judgment of Sentence Entered April 12, 2024 In the Court of Common Pleas of Philadelphia County Criminal Division at No: CP-51-CR-0001917-2023

BEFORE: STABILE, J., NICHOLS, J., and SULLIVAN, J. MEMORANDUM BY STABILE, J.: FILED FEBRUARY 26, 2026 Appellant, Anthony Dingle, seeks review of the judgment of sentence entered by the Court of Common Pleas of Philadelphia County (trial court). In 2024, Appellant was found guilty of possession of a weapon by a prohibited person (18 Pa.C.S.A. § 6105(a)); aggravated assault; carrying a firearm without a license; carrying a firearm on the streets of Philadelphia; possession of an instrument of crime; simple assault; and recklessly endangering another person. He was sentenced to an aggregate prison term of 220 to 440 months. Appellant now argues that his conviction as to the charge of possession of a firearm by a prohibited person must be vacated because, as applied to him, section 6105 violates his constitutional right to bear arms; he contends further that the aggravated portions of his sentence are manifestly excessive due to the trial court’s consideration of improper sentencing factors. Finding no merit in these claims, we affirm.

The underlying case facts have been aptly summarized by the trial court as follows:

At trial, the Commonwealth presented the testimony of Officer Matthew Langan, Officer Brandon Moore, Detective Michael Kimmel, and Detective Eric Cohn, all from the Philadelphia Police Department. Viewed in the light most favorable to the Commonwealth as the verdict winner, the evidence established the following.

At approximately 9:00 a.m. on December 22, 2022, videos from multiple surveillance cameras show [Appellant] driving his white Chevrolet Impala into the parking lot of a Dunkin' Donuts located at the 5500 block of Chestnut Street in Philadelphia. After entering the parking lot, [Appellant] drove into the drive-thru lane, getting in line behind a white Jeep SUV. However, when the Jeep failed to move forward in line as other cars pulled up toward the drive-thru window, [Appellant] drove his car around the Jeep, cutting in front of it. Then, as [Appellant] approached the drive-

thru speaker post and menu, the Jeep lurched forward and bumped the back of [Appellant’s] car, pushing [it] forward.

Moments after the Jeep hit the rear of [Appellant’s] car, [Appellant] exited his car brandishing a black handgun with an extended magazine. High-resolution video from a camera positioned at the drive-thru speaker shows clear images of [Appellant’s] face as [he] exited his car with the gun. [Appellant]

then proceeded to fire his gun 13 times in the direction of the Jeep, which quickly backed out of the parking lot and drove away.

[Appellant] returned to his car, backed out of the drive-thru lane, and exited the parking lot, traveling in the same direction as the Jeep.

When police later responded to the scene, officers found and recovered 13 fired cartridge casings ("FCCs"). All of the FCCs were for .40 caliber bullets. Based upon a review of the video surveillance footage, police identified the license plate number for [Appellant’s] Chevrolet Impala, which was registered in [Appellant’s] name.

Officer Brandon Moore had previously seen [Appellant] driving the same car in March 2022, when Officer Moore had pulled over

[Appellant] for running a stop sign. [Appellant] was not licensed to carry a firearm at the time of the shooting. [Appellant] was also prohibited from possessing a firearm at that time due to his prior conviction for possession with intent to deliver a controlled substance.

Trial Court 1925(a) Opinion, 11/18/2024, at 2-3 (internal citations omitted).

Prior to trial, Appellant filed a motion to dismiss the charge of possession of a weapon by a prohibited person, arguing that, as applied to him, the statutory firearm restriction of section 6105 violated his constitutional right to bear arms. More specifically, Appellant contended that that the ban was unconstitutional because the predicate offense which triggered the restriction was a non-violent crime – possession of a controlled substance with intent to deliver (PWID), 35 Pa.C.S.A. § 780-113(a)(30).

The trial court denied Appellant’s motion, and after the case proceeded to trial, he was convicted and sentenced as outlined above. At the sentencing hearing, the trial court stated on the record that Appellant’s prior conviction in 2012, for unlawfully possessing a firearm, would be taken into account as an aggravating factor. See N.T. Sentencing Hearing, 4/12/2024, at 17. The trial court also expressly considered Appellant’s “conduct throughout the proceedings,” and his “failure to accept any responsibility for his offenses.” Id., at 21. With respect to Appellant’s rehabilitative needs, the trial court acknowledged that Appellant had long struggled with maintaining his mental health. See id., at 19–20.

As to the counts of aggravated assault and unlawful possession of a firearm (pursuant to section 6105), the trial court imposed consecutive prison

terms of 102 to 204 months, both of which were in the aggravated range of the statutory sentencing guidelines; as to the count of possessing an instrument of a crime, the trial court imposed an additional consecutive term of 16-32 months. The aggregate term was 220 to 440 months.

After sentencing, Appellant again raised his constitutional challenge to section 6105 in a post-sentence motion, which was denied. Appellant timely filed a notice of appeal, and he now raises two issues for our consideration:

1. Did the trial court err when it denied [Appellant’s] Motion to Dismiss?

2. Did the trial court err by imposing a manifestly excessive and unreasonable sentence?

Appellant’s Brief, at 4 (suggested answers omitted).

Appellant’s first claim is that section 6105 violates his right to bear arms, as guaranteed by the Second Amendment to the United States Constitution and the Pennsylvania Constitution. 1 He argues, essentially, that the statute’s restriction is only constitutional when the qualifying offenses are violent crimes, and that his own qualifying offense, PWID, was non-violent in nature. See id., at 9-14.

1 The Second Amendment states: “A well regulated Militia, being necessary to

the security of a free State, the right of the people to keep and bear Arms, shall not be infringed.” U.S. Const. amend. II. Article I, section 21 of the Pennsylvania Constitution provides that “[t]he right of the citizens to bear arms in defense of themselves and the State shall not be questioned.” Appellant does not parse his arguments with respect to state and federal constitutional law.

Under subsection 6105e(a), persons are prohibited from possessing firearms if they have been convicted of any offenses enumerated in subsection 6105(b), or if they meet the criteria in subsection 6105(c). See 18 Pa.C.S.A. § 6105(a)(1). Subsection 6105(c), in turn, provides that persons are subject to the statute’s firearm restriction if they have been convicted of an offense under the Controlled Substance, Drug, Device and Cosmetic Act (35 P.S. §§ 780-1 – 780-144), or any equivalent federal or state statute which is punishable by a prison term of over two years. See 18 Pa.C.S.A. § 6105(c)(2).

Here, there is no dispute that Appellant was convicted of a qualifying violation of the Controlled Substances Act (PWID) prior to his arrest in the present case. Under our recent controlling precedent, Appellant’s conviction under section 6105 did not violate his constitutional right to bear arms.

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Com. v. Dingle, A., (Pa. Ct. App. 2026).

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