Com. v. Rothwell, T.

Superior Court of Pennsylvania·Decided August 7, 2026·No. 1855 EDA 2025·Unpublished·Ford Elliott

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

:

v. :

:

:

THEOASIA JASMINE ANNELL :

ROTHWELL :

: No. 1855 EDA 2025

Appellant :

Appeal from the Judgment of Sentence Entered April 8, 2025 In the Court of Common Pleas of Delaware County Criminal Division at No(s): CP-23-CR-0004626-2023

BEFORE: PANELLA, P.J.E., STABILE, J., and FORD ELLIOTT, P.J.E. * MEMORANDUM BY FORD ELLIOTT, P.J.E.: FILED AUGUST 7, 2026 Appellant, Theoasia Jasmine Annell Rothwell, appeals from the judgment of sentence imposed by the Court of Common Pleas of Delaware County after the trial court found her guilty of simple assault, recklessly endangering another person (“REAP”), and harassment. 1 Appellant challenges the trial court’s admission of surveillance videos and the sufficiency of evidence for all her convictions. Upon review, we affirm.

The evidence at trial established that, during the afternoon of May 25, 2023, Officer Mark Crawford of the Chester Police Department received a dispatch call concerning a fight in a convenience store. See N.T. Trial,

* Retired Senior Judge assigned to the Superior Court.

1 See 18 Pa.C.S. §§ 2701(a)(1), 2705, and 2709(a)(1), respectively.

11/13/24, at 7, 9. Upon arriving, he entered the store and observed Appellant, her co-defendant, De’Angela Hatton, and the victim engaged in a “hair pull.” Id. at 8. All three women were taken into custody and given citations. See id. at 34-36. Later, Officer Crawford obtained surveillance videos from the convenience store and charged Appellant and co-defendant Hatton. See id. at 9, 36. (OFFICER CRAWFORD: “Initially[, Appellant and co-defendant] were issued citations because I thought it was a regular [sic] fight, but after I viewed the video and saw the actual actions, [and] that’s when I determined it needed to be criminal.”).

At the bench trial, the Commonwealth introduced into evidence the first surveillance video, and Officer Crawford testified that the video fairly and accurately depicted the store on the day he responded. See N.T. Trial, 11/13/24, at 11-12; Commonwealth Trial Exhibit C-1 (“Surveillance Video One”). Counsel for both Appellant and co-defendant Hatton objected to the video, arguing that it has not been authenticated nor had a chain of custody been established. See N.T. Trial, 11/13/24, at 11-12. The trial court overruled the objection. See id. at 12.2 For Surveillance Video One, Officer Crawford identified Appellant, co-

defendant Hatton, the victim, and the store’s owner in the video. See N.T.

2 Appellant’s counsel also objected on the basis that the videos violated Appellant’s constitutional rights under the Confrontation Clause and the corpus delecti rule. See N.T. Trial, 11/13/24, at 12, 15-16. However, appellate counsel decided to forego argument before this Court on both of those grounds as well as on the chain of custody argument. See Appellant’s Brief at 9, n. 9.

Trial, 11/13/24, at 22-23; Surveillance Video One at 13:11-12. He also identified himself entering the store in the video. See N.T. Trial, 11/13/24, at 23; Surveillance Video One at 13:16. Surveillance Video One depicted Appellant and her co-defendant entering the store and immediately attacking the victim. See N.T. Trial, 11/13/24, at 40.3 Over the next minute, the victim is engaged with co-defendant Hatton while Appellant is seen repeatedly punching the back of the victim’s head and body. See id. at 18.4 During the fight, a metal rod used for hanging chips is dislodged and Appellant proceeded to beat the victim with the rod. See id. at 16-17, 22-23.

Afterwards, the Commonwealth introduced a second video, displaying a different camera angle where the fight continued into a separate aisle. See N.T. Trial, 11/13/24, at 25-26; Commonwealth Trial Exhibit C-2 (“Surveillance Video 2”). This video angle showed a shelf used to store metal canned goods. See N.T. Trial, 11/13/24, at 33. The video demonstrated that Appellant took the canned goods off the shelf and beat the victim with them. See id. at 33, 38.

Additionally, the Commonwealth introduced a third video, which presented another camera angle of the store that captured the fight taking

3 We rely on the trial transcript and the surveillance video timestamps provided therein.

4 The Commonwealth, in its brief, indicates that “[i]n the first minute of the

fight, Appellant punches the victim in the back of the head more than forty times with a closed first.” Appellee’s Brief at 3.

place. See N.T. Trial, 11/13/24, at 23; Commonwealth Trial Exhibit C-3 (“Surveillance Video Three”). Officer Crawford testified that third camera angle captured the front of the store and he identified an ice cream cooler at its entrance. See N.T. Trial, 11/13/24, at 29. Defense counsel for both Appellant and co-defendant Hatton renewed their objections for Surveillance Videos 2 and 3. See N.T. Trial, 11/13/24, at 25, 32.

Appellant did not testify and her defense counsel did not present any other evidence. See id. at 43-46, 48. After the one-day trial ended, the trial court found Appellant guilty of simple assault, REAP, and harassment by physical contact. See Verdict Slip, 11/14/25.5 On April 8, 2025, Appellant was sentenced to an aggregate term of thirty months of probation for all her convictions. See N.T. Sentencing Hearing, 4/8/25, at 11-12; Order (sentencing), 4/8/25. Then, Appellant filed a post- sentence motion seeking a new trial and arguing there was insufficient evidence to sustain her convictions. See Post-Sentence Motion, 4/17/25. On June 26, 2025, the trial court denied Appellant’s post-sentence motion. See Order (denying post-sentence motion), 6/26/25. Appellant filed a timely notice of appeal, and she and the trial court complied with Pennsylvania Rule of Appellate Procedure 1925. See Notice of Appeal, 7/14/25; Rule 1925(b)

5 Co-defendant Hatton was tried with Appellant in a case at docketed at CP-

23-CR-0004627-2023, and was found guilty of simple assault, REAP, and harassment. See Trial Docket Number, CP-23-CR-0004627-2023. The record demonstrates Hatton did not challenge her convictions on appeal. See id.

Order, 7/30/25; Rule 1925(b) Statement, 8/20/25; Trial Court Opinion, 8/28/25.

Appellant raises the following four issues for our review:

I. Whether the trial court erred when over Appellant’s objection, it admitted into evidence video recordings of the alleged incident[,] where the Commonwealth failed to authenticate the videos by presenting sufficient evidence that the recordings were in fact what it claimed them to be when the Commonwealth’s only witness, Officer Mark Crawford, was not present for the entirety of the alleged incident captured in the recordings?

II. Whether the evidence was insufficient to support the charge of [REAP] where the Commonwealth failed to prove beyond a reasonable doubt that the alleged victim was placed in danger of death or serious bodily injury by any act of the Appellant?

III. Whether the evidence was insufficient to support the charge of simple assault where no alleged victim testified about any circumstances surrounding the alleged assault and the Commonwealth failed to prove beyond a reasonable doubt that Appellant intended to cause bodily injury to the alleged victim?

IV. Whether the evidence was insufficient to support the charge of harassment where the Commonwealth failed to prove beyond a reasonable doubt that Appellant intended to harass, annoy[,] or alarm the alleged victim who did not testify?

Appellant’s Brief at 4-5 (answers by trial court omitted).

Appellant, in issue one, argues that the trial court erred in overruling her objection at trial to admission of all three surveillance videos, where the

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