Com. v. Mendoza, H.

CourtSuperior Court of Pennsylvania
DecidedJanuary 26, 2026
Docket859 WDA 2025
StatusUnpublished
AuthorStevens

This text of Com. v. Mendoza, H. (Com. v. Mendoza, 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. Mendoza, H., (Pa. Ct. App. 2026).

Opinion

J-S01045-26

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : HIGINIO MENDOZA : : Appellant : No. 859 WDA 2025

Appeal from the Judgment of Sentence Entered March 19, 2025 In the Court of Common Pleas of Allegheny County Criminal Division at No(s): CP-02-SA-0001726-2024

BEFORE: BOWES, J., PANELLA, P.J.E., and STEVENS, P.J.E.*

MEMORANDUM BY STEVENS, P.J.E.: FILED: January 26, 2026

Appellant, Higinio Mendoza, appeals pro se from the judgment of

sentence entered in the Court of Common Pleas of Allegheny County following

his conviction at a bench trial on the charges of driving an unregistered

vehicle, operating a vehicle without required financial responsibility, and

operating a vehicle without valid inspection.1 After our careful review, we

affirm.

The trial court has set forth the relevant facts and procedural history as

follows:

[Appellant] filed a Summary Appeal from convictions in the Magisterial District Court for [various motor vehicle violations.]

____________________________________________

* Former Justice specially assigned to the Superior Court.

1 75 Pa.C.S.A. §§ 1301(a), 1786(f), and 4703(a), respectively. J-S01045-26

[The matter proceeded to a de novo trial before the trial court on March 19, 2025.] *** During the [trial] on March 19, 2025, the arresting officer, John Cordial, testified that, on October 13, 2024, he conducted a traffic stop on a gray Jeep being driven by [Appellant] which bore inspection stickers expired as of October of 2022. After stopping the vehicle for expired inspection stickers, Officer Cordial’s dispatch center advised him that the registration of the vehicle had expired in September of 2023. Officer Cordial asked [Appellant] for his driver’s license, insurance, and registration. Although [Appellant] eventually produced a driver’s license, he never produced any proof of insurance. Officer Cordial issued [Appellant] citations for the violations of the inspection, registration, and insurance requirements.

Trial Court Opinion, filed 9/8/25, at 1-2.

The trial court convicted Appellant on all charges and sentenced him to

pay mandatory statutory fines totaling $415.00, plus court costs. Appellant

filed a timely pro se notice of appeal. On August 14, 2025, the trial court

ordered Appellant to file a “Statement of Errors Complained of on Appeal”

pursuant to Pennsylvania Rule of Appellate Procedure 1925(b),2 and on August

27, 2025, Appellant filed a timely, pro se Rule 1925(b) statement. On

September 8, 2025, the trial court filed a Rule 1925(a) opinion suggesting

that Appellant’s court-ordered Rule 1925(b) statement raised no coherent

issues, and, thus, Appellant waived all issues for appeal.

2We note the trial court’s Pa.R.A.P. 1925(b) order complies with Pa.R.A.P. 1925(b)(3).

-2- J-S01045-26

Preliminarily, we note it is well settled that “Rule 1925 is a crucial

component of the appellate process because it allows the trial court to identify

and focus on those issues the parties plan to raise on appeal.” Kanter v.

Epstein, 866 A.2d 394, 400 (Pa.Super. 2004). Any issue not raised in a Rule

1925(b) statement will be deemed waived for appellate review. See

Commonwealth v. Lord, 719 A.2d 306, 309 (Pa. 1998). Further, an

appellant’s concise statement must identify the errors with sufficient

specificity for the trial court to identify and address the issues the appellant

wishes to raise on appeal. See Pa.R.A.P. 1925(b)(4)(ii) (requiring a Rule

1925(b) statement to “concisely identify each error that the appellant intends

to assert with sufficient detail to identify the issue to be raised for the judge”).

A Rule 1925(b) concise statement that is too vague can result in waiver of

issues on appeal. See Commonwealth v. Dowling, 778 A.2d 683, 686-87

(Pa.Super. 2001) (“a [c]oncise [s]tatement which is too vague to allow the

court to identify the issues raised on appeal is the functional equivalent of no

[c]oncise [s]tatement at all”). See also Commonwealth v. Ray, 134 A.3d

1109, 1114 (Pa.Super. 2016) (“The Pa.R.A.P.1925(b) statement must be

sufficiently concise and coherent such that the trial court judge may be able

to identify the issues to be raised on appeal.”)).

Here, in his pro se Rule 1925(b) statement, Appellant set forth the

following in its entirety (verbatim):

[Miller versus the US you cannot convert a right into a criminal act.]

-3- J-S01045-26

The definition of a crime is that someone must be hurt or injured, financially physically or a Violation, under statute codes policies regulations, or executive orders, are a commercial Violation. Furthermore, you must be in the activity of or in commerce, and you must be in that jurisdiction for it to be in violation, therefore, having subject matter jurisdiction. Peterson versus Peterson 2014. U.S. SUPREME COURT DECISION--“All codes, rules, and regulations are for government authorities ONLY, not human/Creators in accordance with God’s Laws. All codes, rules, and regulations are unconstitutional and lacking due process.[”] Rodrigues v. Ray Donavan, U.S. Department of Labor, 769 F. 2d 1344, 1348 (1985).[3] For it is with the knowledge that due process was denied to Plaintiff.

Appellant’s Pro Se Pa.R.A.P. 1925(b) Statement, filed 8/26/25 (emphasis in

original) (footnote added).

As indicated supra, the trial court urges this Court to conclude that

Appellant’s Rule 1925(b) statement was so vague and incoherent as to result

in waiver of Appellant’s issues on appeal. We agree that Appellant’s claims

were not made clear to the trial court in a manner which allowed the court to

properly address them, and, thus, Appellant has waived all issues on appeal

for failure to adhere to Pa.R.A.P. 1925(b).

3 We note that Rodrigues, supra, involved a claim brought under the Federal

Compensation Employee Act (“FECA”), 5 U.S.C.A. §§ 8101-8151. The Ninth Circuit Court of Appeals held that the FECA does not require exhaustion of administrative remedies as a prerequisite to a federal district court’s jurisdiction, and, thus, the district court had jurisdiction over the appellant’s claim related to the FECA. Notably, the case sub judice does not arise under the FECA. Moreover, we note the quote, which Appellant attributes to Rodrigues, supra, does not appear therein.

-4- J-S01045-26

Moreover, we note that Appellant’s pro se appellate brief wholly fails to

comply with our Rules of Appellate Procedure, thus impeding meaningful

appellate review. Specifically, Pa.R.A.P. 2111(a) provides that the brief of the

appellant shall consist of, inter alia, the following matters, separately and

distinctly entitled:

(1) Statement of jurisdiction. (2) Order or other determination in question. (3) Statement of both the scope of review and the standard of review. (4) Statement of the questions involved. (5) Statement of the case. (6) Summary of argument. (7) Statement of the reasons to allow an appeal to challenge the discretionary aspects of a sentence, if applicable. (8) Argument for appellant. (9) A short conclusion stating the precise relief sought.

Pa.R.A.P. 2111(a).

Here, Appellant’s appellate brief does not comply in any respect to the

mandates of Rule 2111(a).

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Related

Jones v. Rudenstein
585 A.2d 520 (Superior Court of Pennsylvania, 1991)
Commonwealth v. Lord
719 A.2d 306 (Supreme Court of Pennsylvania, 1998)
Kovalev v. Sowell
839 A.2d 359 (Superior Court of Pennsylvania, 2003)
Commonwealth v. Hardy
918 A.2d 766 (Superior Court of Pennsylvania, 2007)
Commonwealth v. Dowling
778 A.2d 683 (Superior Court of Pennsylvania, 2001)
Com. v. Ray, T., Jr.
134 A.3d 1109 (Superior Court of Pennsylvania, 2016)
Kanter v. Epstein
866 A.2d 394 (Superior Court of Pennsylvania, 2004)

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Bluebook (online)
Com. v. Mendoza, H., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-mendoza-h-pasuperct-2026.