Com. v. Reed, T.

Superior Court of Pennsylvania·Decided July 1, 2026·No. 2133 EDA 2025·Unpublished·Murray

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

Appellant :

:

:

v. :

:

:

TYSHEEN REED : No. 2133 EDA 2025

Appeal from the Order Entered July 9, 2025 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0002939-2025

BEFORE: DUBOW, J., NICHOLS, J., and MURRAY, J. MEMORANDUM BY MURRAY, J.: FILED JULY 1, 2026 The Commonwealth of Pennsylvania appeals from the order granting Tysheen Reed’s (Defendant) motion to quash the charges filed against him, on the grounds that the Commonwealth failed to present prima facie evidence establishing Defendant’s identity as the perpetrator of a shooting. After careful review, we reverse and remand for further proceedings.

On April 25, 2024, at approximately 9:25 p.m., an individual standing on the corner of Broad Street and Susquehanna Avenue in Philadelphia fired multiple gunshots at a vehicle passing through the intersection. Police thereafter recovered four 9mm shell casings from the scene. Police also obtained surveillance video of the shooting, wherein the shooter wore all-black clothing. Additional surveillance video from a nearby subway station depicted Defendant, approximately one minute after the shooting, wearing all-black

clothing. On May 13, 2024, in an unrelated encounter, police found Defendant in possession of a 9mm handgun. Ballistic analysis demonstrated that handgun was the same firearm used in the April 25, 2024, shooting.

The Commonwealth subsequently charged Defendant with one count each of aggravated assault – attempt to cause serious bodily injury, aggravated assault – attempt to cause serious bodily injury with a deadly weapon, carrying a firearm without a license, carrying a firearm on public streets in Philadelphia, possessing an instrument of crime, simple assault, and recklessly endangering another person. 1 At a preliminary hearing on April 23, 2025, the Commonwealth presented testimony from Philadelphia Police Detective Thang Nguyen (Detective Nguyen) and Philadelphia Police Officer Olufemi Bello (Officer Bello), along with surveillance video and a ballistics report.2 At the hearing’s conclusion, the municipal court judge held all charges for court.

1 18 Pa.C.S.A. §§ 2702(a)(1), (a)(4), 6106(a)(1), 6108, 907(a), 2701(a)(1),

2705. The firearm charges pertain to Defendant’s alleged possession of a firearm at the time of the April 25, 2024, shooting. Defendant was charged at a separate docket with his possession of a firearm on May 13, 2024. See Motion to Quash, 6/24/25, at 3 n.3.

2 Defendant stipulated to the ballistics report, which concluded the shell casings recovered from the scene of the April 25, 2024, shooting matched the handgun found in Defendant’s possession on May 13, 2024. See N.T., 4/23/25, at 33; Exhibit C-4 (ballistics report).

On June 24, 2025, Defendant filed a motion to quash/petition for writ of habeas corpus (motion to quash),3 arguing the Commonwealth had failed to present prima facie evidence establishing Defendant’s identity as the shooter. Defendant argued the surveillance videos failed to establish that Defendant was the shooter, and his later possession of the handgun was “insufficient to tip the scales … in the Commonwealth’s favor” because of the three-week passage of time and the frequency with which handguns change hands. Motion to Quash, 6/24/25, at 5.

On July 9, 2025, the trial court held a hearing on the motion to quash, at which the Commonwealth relied on the testimony and exhibits presented at the preliminary hearing, including the surveillance videos and ballistics report. Following the hearing, the trial court entered an order granting Defendant’s motion and quashing all charges.

The Commonwealth timely appealed. 4 The Commonwealth and the trial court have complied with Pa.R.A.P. 1925. The Commonwealth presents the following question for our review:

3 A motion to quash is “the equivalent in Philadelphia practice of a pre-trial

[petition for] writ of habeas corpus,” which is “the proper means for testing whether the Commonwealth has sufficient evidence to establish a prima facie case.” Commonwealth v. Dantzler, 135 A.3d 1109, 1111-12 (Pa. Super. 2016) (en banc).

4 “[A]n order quashing a charge is unquestionably ‘final’ as to that charge….”

Commonwealth v. Karetny, 880 A.2d 505, 512 (Pa. 2005); see also Pa.R.A.P. 341(a) (stating that “an appeal may be taken as of right from any final order”).

Did the [trial] court err in concluding that the Commonwealth failed to establish a prima facie case as to [D]efendant’s identity[,]

when the Commonwealth presented evidence that [D]efendant was present near the scene of the shooting on the date and time in question, was wearing clothing similar to that which was worn by the shooter, and was found in possession of the gun that was used in the shooting less than three weeks after the shooting occurred?

Commonwealth Brief at 5.

Whether the Commonwealth presented sufficient evidence to establish a “prima facie case for a charged crime is a question of law as to which an appellate court’s review is plenary.” Dantzler, 135 A.3d at 1112 (quoting Karetny, 880 A.2d at 513). “[T]he trial court is afforded no discretion in ascertaining whether, as a matter of law and in light of the facts presented to it, the Commonwealth has carried its pre-trial, prima facie burden to make out the elements of a charged crime.” Id. (quoting Karenty, 880 A.2d at 513). Accordingly, “we are not bound by the legal determinations of the trial court.” Id.5 In reviewing an order granting a motion to quash, we are guided by the following principles. To demonstrate that

a prima facie case exists, the Commonwealth must produce evidence of every material element of the charged offense(s) as

5 Instantly, in its Rule 1925(a) opinion, the trial court suggested that appellate

courts employ an abuse of discretion standard when reviewing orders granting motions to quash. See Trial Court Opinion, 9/8/25, at 3-4. However, Dantzler recognized that our Supreme Court rejected that standard in favor of plenary review. Dantzler, 135 A.3d at 1112 (citing Karetny, 880 A.2d at 513).

well as the defendant’s complicity therein. 6 To meet its burden, the Commonwealth may utilize the evidence presented at the preliminary hearing and also may submit additional proof.

Id. (citations and quotation marks omitted; footnote added).

The Commonwealth establishes

a prima facie case when it produces evidence that, if accepted as true, would warrant the trial judge to allow the case to go to a jury. The Commonwealth need not prove the elements of the crime beyond a reasonable doubt; rather, the prima facie standard requires evidence of the existence of each and every element of the crime charged. Moreover, the weight and credibility of the evidence are not factors at this stage, and the Commonwealth need only demonstrate sufficient probable cause to believe the person charged has committed the offense. Inferences reasonably drawn from the evidence of record which would support a verdict of guilty are to be given effect, and the evidence must be read in the light most favorable to the Commonwealth’s case.

Commonwealth v. Smith, 317 A.3d 1053, 1058 (Pa. Super. 2024) (citations and brackets omitted; emphasis in original); see also Dantzler, 135 A.3d at 1111 (“We review a decision to grant a pre-trial petition for a writ of habeas corpus by examining the evidence and reasonable inferences derived therefrom in a light most favorable to the Commonwealth”).

Instantly, the Commonwealth argues the trial court failed to view the evidence in the light most favorable to the Commonwealth and draw

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Related

Commonwealth v. Karetny
880 A.2d 505 (Supreme Court of Pennsylvania, 2005)
Commonwealth v. Terrell
339 A.2d 112 (Superior Court of Pennsylvania, 1975)
Commonwealth v. Dantzler
135 A.3d 1109 (Superior Court of Pennsylvania, 2016)
Com. v. Smith, A.
2024 Pa. Super. 122 (Superior Court of Pennsylvania, 2024)