Com. v. Lopez, J.

2024 Pa. Super. 179, 321 A.3d 1085
CourtSuperior Court of Pennsylvania
DecidedAugust 13, 2024
Docket668 MDA 2023
StatusPublished
Cited by1 cases

This text of 2024 Pa. Super. 179 (Com. v. Lopez, J.) 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. Lopez, J., 2024 Pa. Super. 179, 321 A.3d 1085 (Pa. Ct. App. 2024).

Opinion

J-A15001-24

2024 PA Super 179

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : JESSICA MARIE LOPEZ : : Appellant : No. 668 MDA 2023

Appeal from the Judgment of Sentence Entered April 4, 2023 In the Court of Common Pleas of Lancaster County Criminal Division at No(s): CP-36-CR-0004474-2020

BEFORE: DUBOW, J., BECK, J., and STEVENS, P.J.E.*

OPINION BY DUBOW, J.: FILED: AUGUST 13, 2024

Appellant, Jessica Marie Lopez, appeals from the judgment of sentence

entered on April 4, 2023, in the Court of Common Pleas of Lancaster County

after a jury convicted her of Riot, Criminal Conspiracy to Commit Riot, Failure

of Disorderly Persons to Disperse upon Official Order, Obstructing Highways

and Other Public Passages, Criminal Trespass, and Disorderly Conduct.1

Appellant challenges the trial court’s exclusion of character evidence of her

reputation for involvement in peaceful protests. After careful review, we

affirm.

A.

We glean the relevant factual and procedural history from the trial

court’s Pa.R.A.P. 1925(a) Opinion. On the night of September 13, 2020, ____________________________________________

* Former Justice specially assigned to the Superior Court.

1 18 Pa.C.S. §§ 5501(1), 903(a)(1), 5502, 5507(a), 3503(b)(1)(i), and

5503(a)(1), respectively. J-A15001-24

protestors gathered in front of the Lancaster police headquarters following an

officer-involved shooting. During the ensuing unrest, Appellant assumed a

role of “active leadership and participation[.]” Trial Ct. Op, 8/3/23, at 15.

Video footage showed that, throughout the night, Appellant gave speeches to

the crowd, “orchestrated a blockade” of an adjacent street, was “front and

center” as protestors moved up the ramp of the police headquarters, and

posed for a picture by a dumpster that other protestors had set on fire. Id.

at 13. Appellant and the other protestors did not disperse despite numerous

orders to do so. Police arrested Appellant on September 14, 2020.

The Commonwealth charged Appellant with the above charges, and she

proceeded to a jury trial on November 7, 2022. During her trial, Appellant

attempted to present evidence of her reputation for involvement in peaceful

protests through several character witnesses who knew her from attending

other protests with her. During the first witness’s testimony, the

Commonwealth objected. The court sustained the objection and permitted

the witnesses to testify only to Appellant’s reputation for peacefulness

generally, but not for involvement in peaceful protests. This allowed the

Commonwealth to impeach the witnesses’ testimony with Appellant’s prior

Simple Assault conviction.2

____________________________________________

2 On August 24, 2022, Appellant had filed a motion in limine to exclude evidence of, inter alia, her Simple Assault conviction. On October 6, 2022, the court denied the motion in relevant part, stating that “should [Appellant] choose to present character testimony at trial regarding the character trait of (Footnote Continued Next Page)

-2- J-A15001-24

The jury convicted Appellant of all charges. On April 4, 2023, following

a pre-sentence investigation, the court sentenced Appellant to an aggregate

term of 13 to 30 months of incarceration followed by 3 years of probation, and

ordered her to pay $7,068.17 in restitution. On April 12, 2023, Appellant filed

a timely post-sentence motion, which the court denied on April 17, 2023.

B.

This timely appeal followed. Both Appellant and the trial court complied

with Pa.R.A.P. 1925. Appellant raises one issue for our review:

Did the trial court impermissibly restrict Appellant’s right to present evidence of her reputation for peaceful protest at her trial?

Appellant’s Br. at 4.3

C.

Appellant challenges the trial court’s exclusion of her proffered character

evidence. We review evidentiary rulings for an abuse of discretion.

Commonwealth v. Thompson, 106 A.3d 742, 754 (Pa. Super. 2014). An

abuse of discretion is “the overriding or misapplication of the law, or the

exercise of judgment that is manifestly unreasonable, or the result of bias,

prejudice, ill-will[,] or partiality, as shown by the evidence of record.”

Commonwealth v. Harris, 884 A.2d 920, 924 (Pa. Super. 2005) (citations

omitted). ____________________________________________

peacefulness, the Commonwealth shall be permitted to introduce evidence of [her] conviction for Simple Assault.” Order, 10/6/22, at 1 (unpaginated).

3 Appellant raised 11 other issues in her Rule 1925(b) Statement, but she raised and addressed only this issue in her brief to this Court.

-3- J-A15001-24

A defendant in a criminal case may offer evidence of a “pertinent”

character trait. Pa.R.E. 404(a)(2)(A). Our Supreme Court has defined

“pertinent” to mean “relevant to the crime charged[.]” Commonwealth v.

Minich, 4 A.3d 1063, 1071 (Pa. Super. 2010). It is well-settled that

“[e]vidence of [a defendant’s] good character . . . must be limited to [her]

general reputation for the particular trait or traits of character involved in the

commission of the crime charged. Such evidence must . . . be established by

testimony of witnesses as to the community opinion of the [defendant], not

through specific acts[.]” Commonwealth v. Radecki, 180 A.3d 441, 453–

54 (Pa. Super. 2018) (citation omitted, emphasis added). In addition,

character is “a generalized propensity to act in a certain way without reference

to specific conduct, and frequently contains a normative, or value-laden,

component[,]” such as a character for truthfulness. Pa.R.E. 406 cmt.

Character evidence is inadmissible to prove that a defendant acted in

accordance with that trait on a particular occasion. Pa.R.E. 404(a)(1).

*

Appellant claims that the court erred by excluding evidence of her prior

involvement in peaceful protests and permitting her to put forth only character

evidence of peacefulness generally. Appellant’s Br. at 10, 13-14. She explains

that “a reputation for peacefulness suggests [] that a person would not be

violent under any circumstance[,]” while “[a] reputation for peaceful protest

means that someone would not use violence to redress their political

grievances.” Id. at 13-14. Appellant further argues that her reputation for

-4- J-A15001-24

being involved in peaceful protests was a “pertinent trait” because her intent

in giving her speeches—i.e., whether she intended to cause disorder—was at

issue. Id. at 13. Finally, she asserts that the trial court’s failure to distinguish

between peacefulness generally and involvement in peaceful protest

prejudiced her because the Commonwealth impeached the testimony

asserting her reputation for peacefulness with her Simple Assault conviction

(but could not have impeached her reputation for peacefully protesting

because her Simple Assault conviction was not in the context of a protest).

Id. at 14-15.

During trial, the court stated that “the relevant character trait [is]

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Bluebook (online)
2024 Pa. Super. 179, 321 A.3d 1085, Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-lopez-j-pasuperct-2024.