Com. v. Felder, W.

Superior Court of Pennsylvania·Decided July 31, 2026·No. 737 MDA 2025·Published·Bender

Opinion

J-S18038-26 2026 PA Super 166

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

:

v. :

:

:

WALEEM FELDER :

:

Appellant : No. 737 MDA 2025

Appeal from the Judgment of Sentence Entered March 5, 2025 In the Court of Common Pleas of Lancaster County Criminal Division at No(s): CP-36-CR-0000132-2024

BEFORE: DUBOW, J., BECK, J., and BENDER, P.J.E. OPINION BY BENDER, P.J.E.: FILED: JULY 31, 2026 Waleem Felder (“Appellant”) appeals from the judgment of sentence imposed following his non-jury trial convictions for, inter alia, risking a catastrophe and evading arrest on foot. Appellant challenges the sufficiency of the evidence supporting those two convictions. We agree with Appellant as to risking catastrophe and discharge that conviction. We reject his challenge to the remaining conviction. Because our discharge disrupts the trial court’s sentencing scheme, we vacate and remand for resentencing.1 On November 13, 2023, shortly before 9:30 p.m., Lancaster City police officers Joseph Good and Nathan Parr were on patrol and observed a parked Nissan Altima with windows tinted to the degree Officer Good “was unable to

1 See, e.g., Commonwealth v. Thur, 906 A.2d 552, 569 (Pa. Super. 2006)

(“If our disposition upsets the overall sentencing scheme of the trial court, we must remand so that the court can restructure its sentence plan.”).

see into the passenger compartment to see the occupants.” N.T., 1/7/25, at 9. The Altima, operated by Appellant,2 left its spot. Officers Good and Parr followed and shortly thereafter activated their lights and siren. Id. at 22.

The parties stipulated that “members of the Lancaster City Bureau of Police attempted to stop a vehicle in the area of the 400 block of East End Avenue,” which led to a pursuit “to the first block of South Mulberry Street[.]” Id. at 12. Appellant went through at least two stop signs without slowing; however, departmental policy required the officers to “safely slow down and make sure” the intersection is clear before proceeding. Id. at 31-32. As a result, at some point during the pursuit the officers “could no longer safely keep pace” with Appellant. Id. at 31. Officer Good testified that their speed ranged from 25 to 40 miles per hour. Id. at 35.

Police officers located Appellant’s abandoned vehicle next to a building.

The parties stipulated to the admission of videos captured by cameras operated by the Lancaster Safety Coalition, one of which depicted Appellant “turn[ing] off of Mulberry Street onto High Street, going towards Strawberry. In doing so, it clipped a gas meter on a house on the north side of the northwest side of the intersection. The vehicle then coasted to a stop. The driver exited the vehicle and fled on foot.” Id. at 102. At the time Appellant jumped out, the vehicle was “still [moving] on the sidewalk and str[uck] 305 West Mifflin.” Id. at 41.

2 Appellant challenged identity at trial but does not raise that issue on appeal.

Officers evacuated the building while awaiting a response from the fire department. Id. at 95. Sergeant Christopher Kophamel responded to the scene and testified that the leak risked “fire and any kind of damage to houses and injuries to anybody in that area” had the gas been ignited. Id. at 104. Firefighters ultimately stopped the leak without incident.

The trial court found Appellant guilty of all offenses and sentenced Appellant to an aggregate sentence of 45 months to 12 years’ incarceration. Appellant timely filed a post-sentence motion, which was denied. Appellant thereafter filed a timely notice of appeal and complied with the trial court’s order to file a Pa.R.A.P. 1925(b) statement. The trial court issued its responsive opinion, and the matter is ready for review. Appellant raises two claims:

I. Was the evidence presented by the Commonwealth insufficient to sustain [Appellant’s] conviction for risking catastrophe where he did not recklessly create a risk of catastrophe, as he did not consciously disregard a substantial risk that he would lose control of his car and sever a gas line?

II. Was the evidence presented by the Commonwealth insufficient to sustain [Appellant’s] conviction for evading arrest or detention on foot, where at the time he left his vehicle there was no public servant attempting to lawfully arrest or detain him, as no police officer was present at the scene of the accident nor following him and attempting to arrest him as he traveled on foot to the Shamrock Cafe?

Appellant’s Brief at 7.

Both of Appellant’s claims address whether the Commonwealth presented sufficient evidence to meet its burden to prove his guilt beyond a reasonable doubt. Our standard of review is well-settled. “Because a

determination of the sufficiency of the evidence presents a question of law, our standard of review is de novo and our scope of review is plenary.” Commonwealth v. Ewida, 33 A.3d 1269, 1279 (Pa. Super. 2025) (internal quotation marks and citation omitted).

As a general matter, our standard of review of sufficiency claims requires that we evaluate the record in the light most favorable to the verdict winner giving the prosecution the benefit of all reasonable inferences to be drawn from the evidence. Evidence will be deemed sufficient to support the verdict when it establishes each material element of the crime charged and the commission thereof by the accused, beyond a reasonable doubt.

Commonwealth v. Mumford, 353 A.3d 247, 256 (Pa. Super. 2026) (citation omitted).

Risking a catastrophe

An individual is guilty of risking a catastrophe if he or she “recklessly creates a risk of catastrophe in the employment of fire, explosives or other dangerous means listed in subsection (a) of this section.” 18 Pa.C.S. § 3302(b). The “other dangerous means” set forth within subsection (a) are those capable of “causing potentially widespread injury or damage[.]” Id. § (b).

Appellant’s argument is that the Commonwealth failed to establish the mens rea of recklessness, which is defined as follows:

A person acts recklessly with respect to a material element of an offense when he consciously disregards a substantial and unjustifiable risk that the material element exists or will result from his conduct. The risk must be of such a nature and degree that, considering the nature and intent of the actor’s conduct and the circumstances known to him, its disregard involves a gross

deviation from the standard of conduct that a reasonable person would observe in the actor’s situation.

18 Pa.C.S § 302(b)(3).

Appellant concedes that his act of “fleeing from police in his vehicle was deliberate[.]” Appellant’s Brief at 18. However, he submits that the “loss of control of the vehicle such that it jumped the sidewalk and severed a gas line was purely accidental.” Id. On this point, Appellant notes that the trial court may have concluded that Appellant intentionally struck the gas line. See id. at 19 (“The Commonwealth argued, and the court found that [Appellant] caused his vehicle to ‘strike and destroy a gas meter.’”) (citing Trial Court Opinion, 10/6/24, at 5). Appellant argues that this

is not consistent with the facts, and implies a level of deliberation that simply did not exist. [Appellant] lost control of his vehicle as he was attempting to navigate what police described as a sharp turn onto Mifflin Street and the vehicle left the roadway and struck a house, shearing off a gas line. He did not cause his vehicle to strike and destroy a gas meter—this was clearly an accident.

Id. at 19.

Thus, Appellant suggests that while he may have been guilty of reckless driving, he did not act recklessly with respect to the creation of a “catastrophe” as set forth within Section 3302(a).3 Id. (“While [Appellant] could possibly have been convicted of reckless driving … his driving did not demonstrate a conscious disregard that he would cause widespread injury and damage, which

requires more than a traffic accident.”).

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