Com. v. Sharpe, E.

Superior Court of Pennsylvania·Decided August 6, 2026·No. 3061 EDA 2024·Published·Stabile

Opinion

J-A10002-26 2026 PA Super 178

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

Appellant :

:

:

v. :

:

:

ELIJAH SHARPE : No. 3061 EDA 2024

Appeal from the Judgment of Sentence Entered June 7, 2024 In the Court of Common Pleas of Philadelphia County Criminal Division at No: CP-51-CR-0008684-2023

BEFORE: STABILE, J., LANE, J., and STEVENS, P.J.E.* OPINION BY STABILE, J.: FILED AUGUST 6, 2026 This Commonwealth appeal concerns the reasonableness of a downward departure sentence far below the mitigated range of the sentencing guidelines. In 2024, Elijah Sharpe (Appellee) pleaded guilty to numerous drug related offenses which he had committed while already serving probation in three other similar cases. The standard range under the statutory sentencing guidelines was a prison term of eight to 15 years, with a minimum mitigated range of seven years. However, the Court of Common Pleas of Philadelphia County (trial court) imposed an aggregate prison term of only 11.5 to 23 months, with immediate parole to house arrest, followed by 10 years of probation. The Commonwealth contends that this extreme downward departure was unreasonable because the record as a whole does not reflect a proper consideration of the facts of the crime and character of the offender.

* Former Justice specially assigned to the Superior Court.

Finding merit in the Commonwealth’s claim, we vacate the judgment of sentence and remand for resentencing.

The underlying case facts are not in dispute. Appellee, Elijah Sharpe, was a prominent player in a drug trafficking organization that operated in the Philadelphia neighborhood of Kensington, which is well-known to be one of the largest and most lethal markets for fentanyl in Philadelphia. During the summer and early fall of 2023, the Pennsylvania State Police and Office of the Attorney General were authorized to wiretap telephone calls between Appellee and other members of a suspected conspiracy to distribute narcotics in Kensington.

Appellee can be heard in the intercepted calls directing the distribution and sale of fentanyl and cocaine. That is, these calls demonstrated that Appellee was not a lower-level member of the enterprise. He was instead in control of his own territory within the city block bordered by Shelbourne Street and Hilton Street. Video surveillance of Appellee during this period also showed him both picking up drugs from distribution centers and then supplying “stash houses” in his territory with that contraband. Two of Appellee’s most popular products were baggies of fentanyl “stamped” with the brand names, “Death Row” and “Theraflu.” 1

1 The fentanyl packaged in the baggies was mixed with xylazine, an animal

tranquilizer associated with an increased risk of fatal overdose when ingested by humans. See https://www.cdc.gov/overdose-prevention/about/what-youshould -know-about-xylazine.html (last visited June 8, 2026).

On October 4, 2023, police simultaneously executed search warrants at eight locations in Kensington where Appellee and his associates had been operating. At the three locations directly linked to Appellee, police seized 266 grams of fentanyl/xylazine, 50 grams of methamphetamines, and 236 grams of cocaine and crack cocaine. As evidenced by their volume and packaging (enough for thousands of individual doses), these substances were intended for street sale. See generally N.T. Plea Hearing, 3/22/2024, at 15-17 (recitation of factual predicate of guilty plea). Police also recovered at the residences a small arsenal consisting of an AK-47 Rifle, a 12-gauge shotgun, pistols, ammunition, and other firearm accessories. See Trial Court 1925(a) Opinion, 4/3/2025, at 6-7 (summarizing record facts).

The day after the searches, Appellee and seven co-defendants were criminally charged. Appellee ultimately entered a non-negotiated guilty plea to one count each of possession with intent to deliver (PWID) (35 Pa.C.S.A. § 780-113(a)(30)), criminal conspiracy (18 Pa.C.S.A. § 903), and corrupt organizations (18 Pa.C.S.A. § 911). The trial court ordered a presentence investigation report (PSI) and a mental health evaluation. Both parties filed presentence memoranda.

At Appellee’s sentencing hearing on June 7, 2024, the trial court and the parties agreed that the offense gravity score was 14 for the PWID conviction, and 8 for the corrupt organizations conviction. The parties agreed further that Appellee’s prior record score was 2. Based on those scores, the parties stipulated that the applicable sentencing guidelines for the PWID conviction

were eight to 15 years in the standard range, plus one year in the aggravated range, or minus one year in the mitigated range. As to the corrupt organizations count, the guidelines range was 15 to 20 months, plus or minus nine months. See N.T. Sentencing Hearing 6/7/2024, at 5-7.2 The Commonwealth recommended a standard range prison sentence of nine to 20 years. The severity of this recommendation was intended to be commensurate with Appellee’s status as a high-ranking member in his criminal organization, as well as Appellee’s apparent disregard for human life. The Commonwealth emphasized that Appellee had personally directed the sale and distribution of narcotics, namely fentanyl, despite his full knowledge of the dangers it posed. In fact, Appellee had himself ceased abusing Percocet pills because he feared they could contain fentanyl. See id., at 8-9.

The specifics of Appellee’s role were gleaned in part from intercepted phone calls in which he could be heard instructing his subordinates on what to sell, where to sell it, and how to deal with competitors. As shown in a conversation with a co-defendant, Frank Myers, Appellee was especially keen to hand out “samples” of his products in areas where rival upstarts were encroaching on his territory:

[Appellee]: Let them . . . give out samples. Let them do all that.

By Friday we gonna be loaded up. We gonna hit em with samples all day that day.

2 The offense gravity score for the conspiracy conviction was 14, carrying a

standard guidelines range of 90 months. This count was merged with the PWID conviction for purposes of sentencing.

[Myers]: Alright, he made them . . . draw.

[Appellee]: Man f**k them . . . yo.

[Myers]: I already know.

[Appellee]: That s*** is gonna start a whole war bro. I seen young bull over there gone do something. That s*** is gonna start a whole war. That's gonna shut both us down.

Commonwealth’s Sentencing Memorandum, 5/15/2024, Exhibit C.

In another call with a different conspirator, Appellee was amused by the fact that the potency of his product, “Death Row,” would likely kill one of his customers:

[Appellee] - Aright I'm about to send my girl. I'm about to send m[y] girl up there . . . to give you them samples cause I'm tagging up right now.

[Unidentified] - Aright [okay].

[Appellee] - That's what I'm sayin that shit. That shits some bang though bro so be careful with that shit. Ima give you um.

[Unidentified] - I got you. Aright you gonna give me two different jawns?

[Appellee] - Yea ima give you two. Ima give you two different stamps. Ima give you uh its like uh two, three bags. Ima give you like three bags of the Death row and three bags of Theraflu and you tell me which one you want. Which one better.

[Unidentified] - Aright [okay].

[Appellee] - I know the, I know the Death row gonna be the bang bro its gon probably put somebody down.

[Unidentified]- (laughs) Bro that's crazy.

[Appellee] - You gonna see for yourself ima tell everybody down the way.

Id., at Exhibit H (emphasis added).

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