Com. v. Patterson, E.

CourtSuperior Court of Pennsylvania
DecidedMay 4, 2021
Docket1252 EDA 2020
StatusUnpublished

This text of Com. v. Patterson, E. (Com. v. Patterson, E.) 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. Patterson, E., (Pa. Ct. App. 2021).

Opinion

J-S05028-21

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : ERIK PATTERSON : : Appellant : No. 1252 EDA 2020

Appeal from the Judgment of Sentence Entered February 7, 2020 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0008949-2018

BEFORE: BOWES, J., LAZARUS, J., and McLAUGHLIN, J.

MEMORANDUM BY LAZARUS, J.: FILED MAY 4, 2021

Erik Patterson appeals from the judgment of sentence, entered in the

Court of Common Pleas of Philadelphia County, following his conviction by a jury

of possession of a firearm by a prohibited person.1 After careful review, we

affirm.

The trial court set forth the relevant facts of the case as follows:

On the afternoon of October 31, 2018, Officer Anthony Hurley[, an eleven-year veteran of the Philadelphia police force,] received a radio call that there was an individual wearing a black jacket and blue pants with a gun in the area of a drug treatment facility on 2558 North Front Street in Philadelphia. When Officer Hurley arrived on [the] scene, a security guard and two other individuals were pointing at [Patterson], who was walking nearby on Huntingdon Street, and informed Officer Hurley that [Patterson] had pointed his gun at the security guard. Officer Hurley approached [Patterson], who was wearing a black jacket and blue pants, in his police vehicle and asked [Patterson] to come over to his vehicle. [Patterson] complied[,] and Officer Hurley patted [Patterson] down in order to determine whether [he] had a gun on his person. Office Hurley asked ____________________________________________

1 18 Pa.C.S.A. § 6105. J-S05028-21

[Patterson] what had happened, to which [Patterson] responded that he had gotten into an argument with the security guard because the drug treatment facility had refused to give him treatment.

Officer Hurley then placed [Patterson] in the backseat of the police vehicle so that he could go to speak with the witnesses. Before leaving to speak with the witnesses, however, Officer Hurley noticed [Patterson] fidgeting in the back seat of the vehicle. Officer Hurley then opened the door to the police vehicle and observed [Patterson] attempting to hide a gun magazine under the back seat. Officer Hurley recovered the magazine, which contained seven live rounds of .9mm bullets, and then handcuffed [Patterson]. Subsequently, Officer Hurley noticed a firearm holster on the sidewalk approximately 15 to 20 feet from where Officer Hurley had originally stopped [Patterson]. Officer Hurley also discovered a loaded firearm on top of a box in a trashcan approximately 5 feet from where the firearm holster was recovered. The ammunition in the magazine fit and functioned in the gun that was recovered. Thereafter, [Patterson], who had previously committed an enumerated felony that prohibited him from possessing a firearm, was placed under arrest.

Trial Court Opinion, 8/7/20, at 2-3 (citations to notes of testimony omitted).

Patterson was charged with three violations of the Uniform Firearms Act

(VUFA), 18 Pa.C.S.A. §§ 6105, 6106, and 6108. Prior to trial, Patterson filed a

motion seeking to suppress physical evidence uncovered from the stop on the

following grounds: he was searched and arrested without probable cause; he

was subjected to a stop and frisk on less than reasonable suspicion; and he was

searched and arrested without a warrant. Omnibus Motion, 1/30/19, at 1. After

a hearing before the Honorable Charles Ehrlich on May 31, 2019, the court

denied the suppression motion.

Subsequently, on June 13, 2019, Patterson filed a motion in limine seeking

to exclude “all out-of-court statements [including any reference to a 911 call for

a person with a gun], descriptions [of his appearance, clothing, and direction of

-2- J-S05028-21

travel from the Computer Aided Dispatch (CAD)], and identifications . . .

including pointing [motions] made by unidentified individuals outside 2558 N.

Front Street.” Motion In Limine, 6/13/19, at 1-2.2 Prior to trial, the court heard

argument on Patterson’s motion in limine, after which the court denied the

motion, concluding that the evidence was admissible pursuant to the present

sense impression exception to the rule against hearsay. N.T. Motion In Limine

Hearing/Jury Trial, 8/20/19, at 17-18, 21-22.

Following a two-day trial in August 2019, before the Honorable Glenn B.

Bronson,3 a jury convicted Patterson of the above-stated VUFA offense.4 On

February 7, 2020, the court sentenced Patterson to 10-20 years’ incarceration.5

Patterson filed a post-sentence motion, which the court denied on June 9, 2020.

Patterson then filed a timely notice of appeal and court-ordered Pa.R.A.P.

1925(b) concise statement of errors complained of on appeal. He presents the

following issues for our consideration:

____________________________________________

2 On May 8, 2019, Patterson also filed a motion in limine seeking to exclude “any reference at trial to a ‘black ski mask.’” Motion In Limine, 5/8/19. On August 19, 2019, the court granted that motion. Order, 8/19/19.

3 For reasons unknown to this Court, the case was transferred from Judge Ehrlich to Judge Bronson for trial.

4 The Commonwealth nolle prossed the section 6106 and 6108 charges and proceeded to trial only on the section 6105 offense.

5 Patterson was also held in contempt of court for his threatening behavior towards the trial judge during his sentencing hearing. He was sentenced to a term of 3-6 months’ incarceration for contempt. He has not appealed from that sentence.

-3- J-S05028-21

(1) Did not the court err by failing to suppress evidence for each of the following reasons:

(a) Where the officer arrived on the scene in a marked patrol car with lights and siren activated, then pursued [Patterson] down the street in his car, exited his car with gun drawn, told [Patterson] to approach the car, frisked [Patterson] on the hood of the car and then questioned [him], was not [Patterson] questioned while in custody without being given his Miranda[6] warnings, and should not [Patterson’s] statements have been suppressed, and

(b) Where [Patterson] was then placed in the back of a police car which could not be opened from the inside, was not [Patterson] under arrest in the absence of probable cause, and was not the gun clip subsequently obtained from the back of the police car the product of that illegal arrest and/or the product of forced abandonment due to that illegal arrest, and should not that evidence have been suppressed?

(2) Did not the court err by allowing hearsay statements from persons on the scene (to wit, that [Patterson] had a gun and that [Patterson] pointed the gun at the security guard) to be presented at trial during the testimony of the officer for each of the following reasons:

(a) Where the Commonwealth established no exception for the hearsay, was not the admission of this hearsay improper, and

(b) Even if a portion of this hearsay was otherwise admissible, was not the statement that [Patterson] pointed the gun at the security guard more prejudicial than probative pursuant to Pa.R.E. 403, under the circumstances of the case and the sole charge at issue at trial, and did not the court err by not excluding this portion of the hearsay statements at trial?

6 Miranda v. Arizona, 384 U.S. 436 (1966).

-4- J-S05028-21

Appellant’s Brief, at 4-5.7

In his first issue, Patterson argues that Officer Hurley frisked and

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