Com. v. Lamotta, A.

CourtSuperior Court of Pennsylvania
DecidedDecember 31, 2024
Docket2164 EDA 2023
StatusUnpublished

This text of Com. v. Lamotta, A. (Com. v. Lamotta, A.) 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. Lamotta, A., (Pa. Ct. App. 2024).

Opinion

J-S43040-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : ANTONIO LAMOTTA : : Appellant : No. 2164 EDA 2023

Appeal from the Judgment of Sentence Entered March 1, 2023 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0000079-2021

BEFORE: BOWES, J., STABILE, J., and KUNSELMAN, J.

MEMORANDUM BY KUNSELMAN, J.: FILED DECEMBER 31, 2024

Antonio LaMotta appeals from the judgment of sentence entered after

he was convicted of two violations of the Pennsylvania Uniform Firearms Act

of 1995. 18 Pa.C.S. §§ 6101–6128. He challenges the sufficiency of the

evidence to sustain his conviction for possessing a firearm without a license,

id. § 6106(a)(2), and the constitutionality of the licensing requirement to

carry a firearm in Philadelphia, id. § 6108. We affirm.

On November 5, 2020, LaMotta traveled with Joshua Macias in a silver

Hummer from their home state of Virginia to the City of Philadelphia following

the presidential election. Officers from the Philadelphia Police Department

spoke with LaMotta and Macias at the corner of 12 th Street and Arch Street

near the convention center. Macias stated that they had parked on 13 th Street

and Race Street. One of the officers saw that LaMotta was openly carrying a

black semiautomatic handgun on his hip. The officer saw the imprint of a J-S43040-24

firearm beneath Macias’ sport coat as well. LaMotta indicated that he did not

have a permit to carry the firearm; Macias stated that both men had carry

permits and provided his own documentation.

LaMotta consented to a vehicle search. In the Hummer, police found a

sword, a golf ball launcher, ammunition, and an AM 15 rifle. Police charged

both men with, inter alia, firearms violations. The case ultimately proceeded

to a non-jury trial, where the Commonwealth presented body camera footage

from the search of the Hummer, as well as photographs of the stock of the

rifle under the rear seat and the rifle being held. See N.T., 10/12/22, at 92–

94; Exhibits 18A, 18B. The parties stipulated to a report concluding that the

rifle was operable; however, LaMotta preserved an objection that the report

did not mention the rifle’s length.

The trial court found LaMotta guilty of the two offenses above. On March

1, 2023, the court sentenced LaMotta to serve 11 months 15 days to 23

months of confinement with immediate parole, followed by a consecutive term

of probation. LaMotta appealed.1 LaMotta and the trial court complied with

Pennsylvania Rule of Appellate Procedure 1925.

LaMotta maintains two issues on appeal:

I. Did the trial court err in finding the evidence sufficient to sustain a verdict of guilt[y] for Violation of the Uniform ____________________________________________

1 We treat LaMotta’s appeal as timely filed because the Office of Judicial Records’ order denying his post-sentence motion was entered beyond the 120-day period prescribed by Rule of Criminal Procedure 720, and LaMotta filed his notice of appeal within 30 days of the order. See Commonwealth v. Patterson, 940 A.2d 493, 498–99 (Pa. Super. 2007).

-2- J-S43040-24

Firearms Act § 6106 because the Commonwealth failed to prove that [LaMotta] knowingly, intelligently, or recklessly concealed a firearm as defined under the Uniform Firearms Act?

II. Should [LaMotta’s] conviction for Violation of the Uniform Firearms Act § 6108 be vacated because the statute is unconstitutional under the Pennsylvania and United States Constitutions and the United States Supreme Court’s decision in New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022)?

LaMotta’s Brief at 3 (citation altered).

In his first issue, LaMotta argues there was no evidence that the rifle in

the Hummer met the length requirements to be a “firearm” for purposes of

his Section 6106 conviction. For a sufficiency challenge, “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 . . . .” Commonwealth v. Wright, 255

A.3d 542, 552 (Pa. Super. 2021) (quoting Commonwealth v. Franklin, 69

A.3d 719, 722 (Pa. Super. 2013). Length is a material element for the Section

6106 offense. See Commonwealth v. Mead, _ A.3d _, _, 2024 WL 4646924,

at *4 (Pa. Super. 2024); see also Commonwealth v. Todd, 384 A.2d 1215,

1217–18 (Pa. 1978), superseded by statute on other grounds (requiring

“some evidence” of length under the definition of firearm). 2 ____________________________________________

2 Todd interpreted prior statutory language that applied equally to the offense

of persons not to possess firearms under Section 6105. See Commonwealth v. Gillespie, 821 A.2d 1221, 1224–25 (Pa. 2003) (describing subsequent amendments to Section 6105). The current definition of “firearm” in Section 6102 continues to apply for purposes of Section 6106.

-3- J-S43040-24

The applicable definition of firearm is:

Any pistol or revolver with a barrel length less than 15 inches, any shotgun with a barrel length less than 18 inches or any rifle with a barrel length less than 16 inches, or any pistol, revolver, rifle or shotgun with an overall length of less than 26 inches. The barrel length of a firearm shall be determined by measuring from the muzzle of the barrel to the face of the closed action, bolt or cylinder, whichever is applicable.

18 Pa.C.S. § 6102.

Our courts have affirmed convictions for firearm possession when there

is some evidence to support a factual finding that the length of the gun was

within the applicable definition.3 For example, it was sufficient for a witness

to testify that a gun was concealed in a manila envelope that was “‘about this

high’ and ‘not too wide.’” Commonwealth v. Rozplochi, 561 A.2d 25, 31

(Pa. Super. 1989). Notably, although the record did not indicate the witness’

hand motions, this Court rejected a sufficiency-based challenge of ineffective

assistance of counsel because the judge who had presided would have been

able to observe the witness, estimate the size of the envelope, and conclude

that the gun inside met the definition of a firearm. Id. Likewise, we have

recognized that the Commonwealth may meet its burden to prove the length

of a firearm by entering the firearm itself into evidence. Commonwealth v.

Jennings, 427 A.2d 231, 235 (Pa. Super. 1981). The jury was capable of

determining the length of the weapon by examining it in deliberation. Id.

____________________________________________

3 The cases cited here involved convictions under Section 6105, which at the

time required proof of barrel length. See Note 2, supra. Their reasoning holds true to the present case under Section 6106.

-4- J-S43040-24

Here, there was some evidence of the length of the rifle.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Commonwealth v. Todd
384 A.2d 1215 (Supreme Court of Pennsylvania, 1978)
Commonwealth v. Jennings
427 A.2d 231 (Superior Court of Pennsylvania, 1981)
Commonwealth v. Patterson
940 A.2d 493 (Superior Court of Pennsylvania, 2007)
Commonwealth v. Gillespie
821 A.2d 1221 (Supreme Court of Pennsylvania, 2003)
Commonwealth v. Rozplochi
561 A.2d 25 (Supreme Court of Pennsylvania, 1989)
Commonwealth v. Franklin
69 A.3d 719 (Superior Court of Pennsylvania, 2013)
Com. v. McCormick, E.
2024 Pa. Super. 212 (Superior Court of Pennsylvania, 2024)
Com. v. Wright, B.
2021 Pa. Super. 119 (Superior Court of Pennsylvania, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
Com. v. Lamotta, A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-lamotta-a-pasuperct-2024.