Com. v. Felder, H.

2021 Pa. Super. 21, 247 A.3d 14
CourtSuperior Court of Pennsylvania
DecidedFebruary 17, 2021
Docket2994 EDA 2019
StatusPublished
Cited by31 cases

This text of 2021 Pa. Super. 21 (Com. v. Felder, H.) 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. Felder, H., 2021 Pa. Super. 21, 247 A.3d 14 (Pa. Ct. App. 2021).

Opinion

J-S48005-20

2021 PA Super 21

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : HAKIEM FELDER : : Appellant : No. 2994 EDA 2019

Appeal from the Judgment of Sentence Entered May 9, 2019, in the Court of Common Pleas of Philadelphia County, Criminal Division at No(s): CP-51-CR-0002227-2018.

BEFORE: KUNSELMAN, J., KING, J., and McCAFFERY, J.

OPINION BY KUNSELMAN, J.: FILED FEBRUARY 17, 2021

Hakiem Felder appeals from the judgment of sentence imposing three

to six years’ incarceration, following his non-jury conviction of three violations

of the Uniform Firearms Act.1 Felder and the Commonwealth believe after-

discovered evidence necessitates a new trial. However, because the trial court

acted within its discretion when it denied the new-trial request, we affirm.

The trial court related the following facts:

On December 30, 2017, at around 11:00 p.m., Philadelphia Police Officer Michael Schmidt and his partner, Officer Marc Marchetti, were on patrol . . . Officer Schmidt observed [Felder] look in the direction of the officers’ police car and then make a motion as if he were removing a silver- covered object from his waistband. [Felder] then went behind a car, at which time Officer Schmidt heard what ____________________________________________

1 18 Pa.C.S.A. § 6105 (possessing a firearm when prohibited), 18 Pa.C.S.A. §

6106 (carrying without a license), and 18 Pa.C.S.A. § 6108 (carrying a firearm on the streets of Philadelphia). J-S48005-20

sounded like a metallic object hitting the ground. Whatever the object was, it made a sound when it hit the pavement.

[Next,] Officer Marchetti stopped the patrol car, and Officer Schmidt began a conversation with [Felder] about a recent fight. While Officer Schmidt spoke to [Felder], Officer Marchetti went to look for the object [Felder] appeared to drop. He returned shortly thereafter and indicated that he had recovered a handgun loaded with nine rounds. The officers then placed [Felder] under arrest. Once inside the patrol car, [Felder] volunteered that the officers could not have heard the gun hit the ground, because there was snow on the ground.

Trial Court Opinion, 5/18/2020, at 1-2.

At trial, both of the officers testified that they observed Felder remove

something from his waistband and both of them heard a metal object hit the

ground. See N.T., 2/27/19, at 9, 18-19, 20, 26, 31-32. Officer Marchetti also

heard Felder confess to dropping the gun. See id. at 30-31. “While we were

seated in the vehicle, [Felder] stated as a blurt – utterance – he said, ‘There’s

no way you could’ve heard that; it hit the sidewalk; there’s snow on there.”

Id.

The trial court found Felder guilty of three firearms offenses. Thereafter,

the Commonwealth realized it failed to disclose 2018 court records that could

have weakened Officer Schmidt’s credibility. The Commonwealth described

those records, from two unrelated cases, as follows:

in April 2018 and September 2018, judges in two separate cases had found that both Officer Schmidt and [another officer] had testified incredibly about what led them to stop and search two individuals in unrelated incidents in March 2017. At the time of trial, those decisions were in the Commonwealth’s possession, but the prosecuting district attorney was unaware of them.

-2- J-S48005-20

In the first case, Officer Schmidt and his then-partner, Officer Edward Wright, both testified that, while on patrol on March 2, 2017, they were able to smell the strong scent of fresh marijuana emanating from a vehicle. Officer Schmidt testified that he was able to smell that odor through the windows of their patrol car from approximately two house- lengths away (or 30 feet). In an unpublished order, a judge of the Court of Common Pleas determined that both officers had given incredible testimony and that they “could not, and did not, detect the odor of marijuana emanating from the” vehicle. Order at 2-3, Commonwealth v. Dill, CP-51-CR- 0002316-2017 (C.P. Philadelphia May 9, 2018).

In the other case, Officer Schmidt and Officer Wright testified that, while on patrol on March 11, 2017, they had both “noticed a man crouch behind the passenger side of a parked car after looking toward the officers as they drove past.” The officers testified that, after they stopped to investigate, they “could immediately smell the odor of fresh marijuana coming from inside the vehicle.” In an unpublished memorandum opinion, a U.S. District Judge concluded that both officers had again testified incredibly. The court wrote that “several factors led it to that conclusion: the inconsistency and embellishment of the officers’ testimony; a previous adverse credibility finding against both officers in [Dill, supra]; and the unlikeliness of the officers’ ability to smell the marijuana, given its packaging, weight, and location in the car.” Mem. Op. at 2- 3, 12, United States v. Harrison, No. 17-228 (E.D. Pa. Sept. 17, 2018).

Promptly after learning of the two decisions, the assistant district attorney disclosed them to [Felder’s] counsel by phone call and e-mail.

Commonwealth’s Brief at 4-7 (some punctuation and citations omitted).

Based on the 2018 court records, Felder moved for extraordinary relief

pursuant to Pennsylvania Rule of Criminal Procedure 704(B). Specifically, he

sought a new trial due to after-discovered evidence. The trial court denied

Felder’s motion and sentenced him as described above.

-3- J-S48005-20

This timely appeal followed.

Felder raises one issue on appeal. He asks this court:

Should the trial court have granted . . . extraordinary relief in the interest of justice, when [he] and the Commonwealth learned after trial, but prior to sentencing, that [Officer Schmidt] had been deemed to be non-credible by one state and one federal judge?

Felder’s Brief at 4.

A criminal defendant seeking to assail a guilty verdict and retry a case

with after-discovered evidence must clear four hurdles. He must convince the

trial court “that the evidence (1) could not have been obtained prior to the

conclusion of the trial by the exercise of reasonable diligence; (2) is not merely

corroborative or cumulative; (3) will not be used solely to impeach the

credibility of a witness; and (4) would likely result in a different verdict if a

new trial were granted.” Commonwealth v. Padillas, 997 A.2d 356, 363

(Pa. Super. 2010). “The test is conjunctive; the defendant must show by a

preponderance of the evidence that each of these factors has been met in

order for a new trial to be warranted.” Id.

If the trial court does not grant a new trial, the four hurdles become

even harder to clear on appeal due to our scope and deferential standard of

review.2 Nearly a century ago, the Supreme Court of Pennsylvania stated that ____________________________________________

2 “The bar continually struggles with what these terms mean, as well as with

ascertaining and applying the appropriate standard and scope of review to a given issue on appeal.” Jeffery P. Bauman, Standards of Review and Scopes of Review in Pennsylvania — Primer and Proposal, 39 Duq. L. Rev. 513 (2001).

-4- J-S48005-20

the implications of after-discovered evidence “are peculiarly within the

discretion of the trial court.” Simmons-Boardman Pub. Co. v. Am. Boron

Prod. Co., 128 A. 511, 511 (Pa. 1925) (emphasis added). Hence, when

reviewing such matters, our standard of review is “an abuse of discretion.”

Padillas at 361.

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Bluebook (online)
2021 Pa. Super. 21, 247 A.3d 14, Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-felder-h-pasuperct-2021.