Com. v. Jones, T.

Superior Court of Pennsylvania·Decided May 23, 2022·No. 1250 WDA 2021·Unpublished

Opinion

J-S14044-22

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : TAI JAUNA LASHAE JONES : : Appellant : No. 1250 WDA 2021

Appeal from the Judgment of Sentence Entered August 30, 2021 In the Court of Common Pleas of Allegheny County Criminal Division at No(s): CP-02-CR-0004212-2020

BEFORE: McLAUGHLIN, J., McCAFFERY, J., and PELLEGRINI, J.*

MEMORANDUM BY PELLEGRINI, J.: FILED: MAY 23, 2022

Tai Jauna Lashae Jones (Jones) appeals from the judgment of sentence

imposed by the Court of Common Pleas of Allegheny County (trial court)

following her non-jury convictions for robbery, receiving stolen property,

defiant trespass and harassment.1 On appeal, she challenges the admission

of several text messages from the victim’s cell phone, arguing that the

Commonwealth failed to properly authenticate the text messages because it

could not prove that she sent them. After review, we affirm.

At the non-jury trial, Dazzae Perkins (Perkins) testified that four women

attacked her from behind while she was leaving her home for work on April 7,

____________________________________________

* Retired Senior Judge assigned to the Superior Court.

1 18 Pa.C.S. §§ 3701(a)(1)(v), 3925(a), 3503(b)(1)(i) and 2709(a)(1). J-S14044-22

2020. Perkins identified Jones as one of the attackers and stated that Jones

hit her and took her purse with her iPhone in it. Perkins went to the hospital

later that day and was diagnosed with a mild concussion.

Perkins testified that a few days after the attack, she was with her

daughter when her daughter received several text messages from her stolen

iPhone. Jones’ counsel objected and argued that the Commonwealth could

not authenticate the text messages because there was no evidence that Jones

sent them. The Commonwealth countered that it was not claiming that Jones

sent the text messages, but it was offering the text messages to establish that

the phone was stolen because those messages were sent by someone other

than Perkins. Jones’ counsel persisted that the messages could not be

admitted until they were authenticated and the trial court overruled the

objection in the following exchange:

[DEFENSE COUNSEL]: Judge, my argument is you can’t admit [the text messages] until you have made a determination as to authentication. And I will point to – this is a relatively new Rule of Evidence, Rule 901(b)(11), governing authentication by identification of digital evidence.

It states to connect digital evidence to a person or entity, there is two ways to do it; one, direct evidence, such testimony of a person with personal knowledge. So if someone can say I actually watched the defendant send this text message, that would be relevant; or through circumstantial evidence such as identifying content or proof of ownership, possession, control or access to the device during the relevant time corroborated by circumstances indicating ownership.

[ADA]: Which, Your Honor, I would argue that I would be able to do that through these text messages. I haven't gotten there yet, but the witness would be able to testify that these were the texts

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that she saw coming through to her daughter's phone via her iPad. I would argue that she would be able to establish the date being close in time to when this phone was stolen. And furthermore, she was able to testify that it was Ms. Jones who stole her phone.

THE COURT: So why is that not circumstantial evidence? Overruled. Go ahead.

Id. at 19-20.

After the trial court’s ruling, Perkins testified that she saw her daughter

receive the text messages that were being sent from iPhone. While she did

not know who was sending the messages, Perkins noted that the messages

referred to her in the third person.

At the end of trial, Jones was found guilty of the above-listed offenses

and sentenced to serve nine months’ probation. After the denial of her post-

sentence motion, she filed this timely appeal.

On appeal, Jones contends that the trial court abuse its discretion in

admitting the text messages from Perkins’ phone because the Commonwealth

did not properly authenticate them to establish that Jones was the sender.2

Pennsylvania Rule of Evidence 901 sets forth the standards for

authenticating evidence. Rule 901 states, in relevant part, as follows:

(a) In General. Unless stipulated, to satisfy the requirement of authenticating or identifying an item of evidence, the proponent ____________________________________________

2 “Rulings on admissibility are committed to the common pleas court’s discretion and will only be reversed on appeal where there is an abuse of discretion.” Commonwealth v. Rogers, 250 A.3d 1209, 1215 (Pa. Super. 2021) (citation omitted). “An abuse of discretion occurs when the law is overridden or misapplied, or the judgment exercised was either manifestly unreasonable or the product of partiality, prejudice, bias, or ill will.” Id.

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must produce evidence sufficient to support a finding that the item is what the proponent claims it is.

(b) Examples. The following are examples only--not a complete list--of evidence that satisfies the requirement:

***

(11) Digital Evidence. To connect digital evidence with a person or entity:

(A) direct evidence such as testimony of a person with personal knowledge; or

(B) circumstantial evidence such as:

(i) identifying content; or

(ii) proof of ownership, possession, control, or access to a device or account at the relevant time when corroborated by circumstances indicating authorship.

Pa.R.E. 901.

“Digital evidence,” as used in this rule, is intended to include a communication, statement, or image existing in an electronic medium. This includes emails, text messages, social media postings, and images. The rule illustrates the manner in which digital evidence may be attributed to the author.

The proponent of digital evidence is not required to prove that no one else could be the author. Rather, the proponent must produce sufficient evidence to support a finding that a particular person or entity was the author. See Pa.R.E. 901(a).

Pa.R.E. 901, cmt.

Under Pennsylvania Rule of Evidence 901, text messages may be authenticated by: (1) testimony from either the author or the sender; (2) circumstantial evidence, including “distinctive characteristics” like information specifying the author-sender or “reference to or correspondence with relevant events” preceding or following the message; or (3) “any other facts or aspects of the

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message that signify it to be what its proponent claims.” Commonwealth v. Koch, ... 106 A.3d 705, 712-13 ([Pa.] 2014) (Castille, C.J., in support of affirmance); see Commonwealth v. Collins, ... 957 A.2d 237, 265-66 ([Pa.] 2008). Further, “authentication generally entails a relatively low burden of proof; in the words of Rule 901 itself, simply ‘evidence sufficient to support a finding that the item is what the proponent claims.’ ” Koch, 106 A.3d at 713 (quoting Pa.R.E. 901(a)).

Commonwealth v. Murray, 174 A.3d 1147, 1156-57 (Pa. Super. 2017)

(brackets omitted). “[A]uthentication social media evidence is to be evaluated

on a case-by-case basis to determine whether or not there has been an

adequate foundational showing of its relevance and authenticity.”

Commonwealth v.

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