Com. v. Mitchell, T.

CourtSuperior Court of Pennsylvania
DecidedJanuary 10, 2025
Docket2270 EDA 2023
StatusUnpublished

This text of Com. v. Mitchell, T. (Com. v. Mitchell, T.) 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. Mitchell, T., (Pa. Ct. App. 2025).

Opinion

J-S23038-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : TIMOR MITCHELL : : Appellant : No. 2270 EDA 2023

Appeal from the Judgment of Sentence Entered April 14, 2023 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0002896-2022

BEFORE: STABILE, J., KING, J., and COLINS, J.*

MEMORANDUM BY COLINS, J.: FILED JANUARY 10, 2025

Appellant Timor Mitchell appeals from the judgment of sentence

imposed following his convictions of aggravated assault and related crimes

stemming from an incident at a beer distributor. We affirm.

The trial court offered the following factual history of this matter:

On March 17, 2022, at 8:45pm, Appellant entered a business located at 2517 W. Girard Avenue. Notes of Testimony (hereinafter “N.T.”), 2/1/23 at 33-37. Immediately thereafter, Subhsub Tehlan (hereinafter “Mr. Tehlan”) the owner of the store requested Appellant leave the premises, as he had informed the Appellant on March 14, 2022 to “leave the business, and not come back.” Id. When Appellant failed to comply, Mr. Tehlan retrieved a wooden baseball bat and forced Appellant towards the front door. At that point, Appellant pulled a handgun from his bag, placed it at Mr. Tehlan’s stomach and said “give me the money” several times. Id. at 30-32. Appellant forced Mr. Tehlan towards the cash register and a struggle ensued, causing the handgun to discharge. Id. at 43. ____________________________________________

* Retired Senior Judge assigned to the Superior Court. J-S23038-24

Police responded to the location in response to calls “for a robbery in progress - point of gun.” Id. at 50. Upon arrival they found Mr. Tehlan holding the Appellant at gunpoint. Id. at 52. Mr. Tehlan was not shot during the incident, but sustained injuries to his right hand during the struggle for the firearm. From these injuries, he underwent surgery and physical therapy. Id. at 40- 42. Police recovered video footage of the incident (with sound) and Appellant was subsequently arrested. Appellant did not have a license to carry a firearm on the date of [the] incident as presented in Commonwealth exhibit C8. The parties stipulated that Appellant was unable to possess a firearm due to a conviction of a qualifying non-possessory offense.

Trial Court Opinion, 11/1/23, at 2-3.

On January 3, 2023, Appellant underwent a mental health evaluation to

determine his competency to stand trial. The psychiatrist determined

Appellant was competent and the matter was scheduled for trial on February

1, 2023.

At the proceedings on February 1, 2023, defense counsel requested an

additional competency examination. The trial court conducted an extensive

colloquy, determined that Appellant was competent to waive his right to a trial

by jury, and commenced a waiver trial. The trial court convicted Appellant of

aggravated assault, robbery, possession of firearm prohibited, firearms not to

be carried without a license, carrying firearms on public streets in Philadelphia,

criminal attempt, possession of an instrument of crime, criminal mischief,

simple assault, and recklessly endangering another person. 1 On April 14,

____________________________________________

1 18 Pa.C.S. §§ 2702, 3701, 6105, 6106, 6108, 901, 907, 3304, 2701, and

2705, respectively.

-2- J-S23038-24

2023, the trial court sentenced Appellant to serve an aggregate term of

incarceration of twelve to twenty-four years. Appellant’s post-sentence

motions were denied, and this timely appeal followed.

Appellant presents the following issues for our review:

I. Did the lower court abuse its discretion when it denied defense counsel’s request for a competency evaluation the morning of trial?

II. Did the lower court abuse its discretion when it accepted [Appellant’s] waiver of his right to a jury trial?

III. Was the evidence sufficient to prove robbery and aggravated assault, where the Commonwealth did not prove that [Appellant] had the specific intent to cause serious bodily injury or to take the victim’s property?

Appellant’s Brief at 4 (suggested answers omitted).

Appellant first argues that the trial court erred in denying defense

counsel’s request for an additional competency examination on the morning

of Appellant’s trial. See Appellant’s Brief at 10-13. Appellant asserts that,

even though Appellant had been the subject of a psychiatric exam four weeks

prior to trial, the trial court abused its discretion in denying an additional

competency examination in light of Appellant’s apparently confused behavior

at the proceedings. Basically, Appellant contends the trial court erred in failing

to grant a continuance in order to allow a second competency examination.

“The matter of granting or denying a continuance is within the discretion

of the trial court.” Commonwealth v. Sandusky, 77 A.3d 663, 671 (Pa.

Super. 2013) (citation omitted). “[T]rial judges necessarily require a great

-3- J-S23038-24

deal of latitude in scheduling trials.” Id. (citation omitted). “Accordingly, a

trial court exceeds its constitutional authority only when it exercises its

discretion to deny a continuance on the basis of an unreasoning and arbitrary

insistence upon expeditiousness in the face of a justifiable request for delay.”

Id. at 671-72 (citation and quotation marks omitted).

Pursuant to the Mental Health Procedures Act, a defendant must be

competent in order to be tried, convicted, or sentenced. 50 P.S. § 7402(a).

A defendant is presumed to be competent to stand trial. Commonwealth v.

Brown, 872 A.2d 1139, 1156 (Pa. 2005). The burden is on the defendant to

prove that he was incompetent to stand trial. See id. To do so, he must

establish that “he was either unable to understand the nature of the

proceedings against him or to participate in his own defense.” Id.

Competency to stand trial is measured by the relationship between counsel and client: To be deemed competent, the defendant needs to have the ability to consult with counsel with a reasonable degree of understanding, in order to participate in his defense, and he must be able to understand the nature or object of the proceedings against him. The focus is properly on the defendant’s mental capacity, i.e., whether he has the ability to understand the proceedings.

Commonwealth v. Blakeney, 108 A.3d 739, 752 (Pa. 2014) (citations

omitted). We review a trial court’s determination regarding a defendant’s

competency for abuse of discretion. Commonwealth v. Bomar, 826 A.2d

831, 860 (Pa. 2003).

In addressing this claim, the trial court offered the following:

-4- J-S23038-24

As background, the [trial c]ourt notes that there was, in fact, a pre-trial determination of Appellant’s competency. On January 4, 2023 - less than 30 days prior to trial in this matter- John S. O’Brien II, M.D., J.D. (hereinafter “Dr. O'Brien”) evaluated the Appellant. In his report, Dr. O’Brien states:

[Appellant] is specifically aware of his current circumstances and able to appropriately communicate about them sufficiently so as to be able to understand the nature and object of legal proceedings and participate and assist in them.

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

Related

Commonwealth v. Charlton
902 A.2d 554 (Superior Court of Pennsylvania, 2006)
Commonwealth v. Emler
903 A.2d 1273 (Superior Court of Pennsylvania, 2006)
Commonwealth v. Galindes
786 A.2d 1004 (Superior Court of Pennsylvania, 2001)
Commonwealth v. Wilson
825 A.2d 710 (Superior Court of Pennsylvania, 2003)
Commonwealth v. Brown
872 A.2d 1139 (Supreme Court of Pennsylvania, 2005)
Commonwealth v. Robertson
874 A.2d 1200 (Superior Court of Pennsylvania, 2005)
Commonwealth v. Butler
729 A.2d 1134 (Superior Court of Pennsylvania, 1999)
Commonwealth v. Mallory
941 A.2d 686 (Supreme Court of Pennsylvania, 2008)
Commonwealth v. Chopak
615 A.2d 696 (Supreme Court of Pennsylvania, 1992)
Commonwealth v. Bomar
826 A.2d 831 (Supreme Court of Pennsylvania, 2003)
Commonwealth v. Houck
948 A.2d 780 (Supreme Court of Pennsylvania, 2008)
Commonwealth v. Sanchez
36 A.3d 24 (Supreme Court of Pennsylvania, 2011)
Commonwealth v. Garland
63 A.3d 339 (Superior Court of Pennsylvania, 2013)
Commonwealth v. Sandusky
77 A.3d 663 (Superior Court of Pennsylvania, 2013)
Commonwealth v. Trinidad
96 A.3d 1031 (Superior Court of Pennsylvania, 2014)
Commonwealth v. Blakeney
108 A.3d 739 (Supreme Court of Pennsylvania, 2014)
Com. v. Bonnett, P.
2020 Pa. Super. 231 (Superior Court of Pennsylvania, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Com. v. Mitchell, T., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-mitchell-t-pasuperct-2025.