Com. v. Watson, N.

CourtSuperior Court of Pennsylvania
DecidedJune 4, 2025
Docket727 EDA 2024
StatusUnpublished

This text of Com. v. Watson, N. (Com. v. Watson, N.) 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. Watson, N., (Pa. Ct. App. 2025).

Opinion

J-S09018-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : NIBRI WATSON : : Appellant : No. 727 EDA 2024

Appeal from the Judgment of Sentence Entered February 5, 2024 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0005670-2022

BEFORE: LAZARUS, P.J., BECK, J., and STEVENS, P.J.E.*

MEMORANDUM BY BECK, J.: FILED JUNE 4, 2025

Nibri Watson (“Watson”) appeals from the judgment of sentence

imposed by the Philadelphia County Court of Common Pleas (“trial court”)

following his convictions of first-degree murder, carrying a firearm without a

license, carrying a firearm on the public street in Philadelphia, and possession

of an instrument of crime.1 Watson raises a challenge to the sufficiency of the

evidence to support his conviction based upon the alleged dearth of evidence

to establish that he committed the murder, and claims that the trial court

abused in discretion in permitting the introduction of biographical information

from a prior arrest form. Upon review, we affirm.

____________________________________________

* Former Justice specially assigned to the Superior Court.

1 18 Pa.C.S. §§ 2502(a)(1), 6106(a)(1), 6108, 907(a). J-S09018-25

The trial court set forth the relevant underlying facts:

At around 8 p.m. on September 14, 2021, [Watson] was in the parking lot of Liberty Gas Station at 101 West Leigh Avenue in Philadelphia. N.T.[,] 2/1/[20]24[,] at 68, 71-72, 74; Commonwealth Exhibit C-57 (Surveillance Video Compilation). During the time [Watson] was in the parking lot of the gas station, three individuals, Kamaj Rudd [(“Rudd”)], Johnathan Dell [(“Dell”)], and an unknown third man, arrived at the gas station and went inside while [Watson] remained in the parking lot. N.T.[,] 2/1/[20]24[,] at 68, 74-75; Commonwealth Exhibit C-57 (Surveillance Video Compilation). Upon exiting the gas station, Rudd, Dell, and the unknown man approached [Watson] as he stood outside and robbed him at gun point. N.T.[,] 2/1/[20]24[,] at 17, 68, 76-77; Commonwealth Exhibit C-57 (Surveillance Video Compilation).

After robbing [Watson], the three men immediately fled, running away from the gas station towards North Howard Street. N.T.[,] 2/1/[20]24[,] at 68, 77; Commonwealth Exhibit C-57 (Surveillance Video Compilation). A few seconds after the three men started to run, [Watson], who had a gun concealed in his waistband, began chasing them. N.T.[,] 2/1/[20]24[,] at 68, 77- 78; Commonwealth Exhibit C-57 (Surveillance Video Compilation). Once on North Howard Street, the three men who robbed [Watson] ran towards a black sedan. N.T.[,] 2/1/[20]24[,] at 68, 78-80; Commonwealth Exhibit C-57 (Surveillance Video Compilation). Two of the men, Dell and the unknown man, got into the sedan and quickly sped away from [Watson]. N.T.[,] 2/1/[20]24[,] at 68, 78-80; Commonwealth Exhibit C-57 (Surveillance Video Compilation). As the car sped off, [Watson], who had since drawn his gun, shot Rudd multiple times in the back after Rudd, who was lagging behind, tripped in his attempt to catch up to the car. N.T.[,] 2/1/[20]24[,] at 68, 78-80; Commonwealth Exhibit C-57 (Surveillance Video Compilation). After shooting Rudd, [Watson] fled the scene. N.T.[,] 2/1/[20]24[,] at 68, 80; Commonwealth Exhibit C-57 (Surveillance Video Compilation).

Following the shooting, medics and police promptly arrived at North Howard Street to find Rudd lying face down in a pool of blood on the sidewalk. N.T.[,] 2/1/[20]24[,] at 84-85. Rudd was assessed by medics and subsequently transported to Temple University Hospital, where he was pronounced dead during the

-2- J-S09018-25

early morning hours of September 15, 2021. N.T.[,] 2/1/[20]24[,] at 89, 92. The medical examiner determined the cause of Rudd’s death was multiple gunshot wounds, and the manner of death was homicide. N.T.[,] 2/2/[20]24[,] at 33-36. [Watson] was not licensed to carry a firearm on the date of the shooting. Id. at 36.

Trial Court Opinion, 6/6/2024, at 2-3.

Police arrested Watson and charged him with numerous crimes. The

matter proceeded to a jury trial. Pertinently, at trial, the Commonwealth

introduced a compilation video that contained footage from surveillance

cameras near the scene of the robbery and shooting. The video showed the

shooter to be left-handed. As a result, the Commonwealth sought to introduce

into evidence Watson’s Pennsylvania criminal history, which compiled

biographical information from Form 75-229,2 and showed that Watson was

left-handed. Watson’s counsel objected to the introduction of this evidence,

arguing the Commonwealth did not provide it during discovery and the

biographical information could not be admitted because Watson had not been

provided with Miranda3 warnings when this information was taken. The trial

court rejected both of Watson’s claims and admitted the evidence.

2 Form 229 is a biographical information report completed after an individual

is arrested. Form 229 collects basic information about the arrestee, including the person’s name, address, date of birth, and other relevant details. In this case, the information presented was derived from a 229 form completed after Watson was arrested as a juvenile.

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

-3- J-S09018-25

The jury ultimately found Watson guilty of the above-mentioned crimes.

The trial court sentenced Watson to an aggregate term of life in prison.

Watson filed a timely appeal, raising the following claims for our review:

1. Where the Commonwealth’s case relied solely upon video and cell phone evidence, and the video evidence reflected that [Watson’s] skin tone and facial features were different than that in the videos, was the evidence insufficient as a matter of law to identify [Watson] as the doers [sic] of these crimes?

2. Where the Commonwealth sought to admit a booking statement which only provided to the defense at trial, did the lower court improperly reward the Commonwealth for its misconduct by not finding that the Commonwealth lack of notice and the prejudicial nature of this evidence did not warrant its exclusion from trial?

3. Where the booking statement contained evidence which incriminated [Watson] and was not general information, did the lower court err in not concluding that [Watson’s] statement to the police was inadmissible due to a lack of Miranda warnings?

Watson’s Brief at 3.

Sufficiency of the Evidence

Watson argues the evidence was insufficient to support his convictions

because the Commonwealth failed to prove he committed the crimes. Id. at

8, 13. He contends that the Commonwealth’s evidence relied on two people

—his stepfather, Darryl Taylor (“Taylor”) and Detective Thorsten Lucke. Id.

at 9, 10. Regarding Detective Lucke, Watson claims that he “superimposed

an allegedly known photo of Watson against that of the person in a composite

video at the Liberty Gas Station.” Id. at 9. According to Watson, “the known

-4- J-S09018-25

photo superimposed on the video inside the Liberty Gas Station, reflects a skin

color and a nose which are far different from the known photo of the person

who the Commonwealth claims is Watson.” Id. He further highlights that

Taylor never definitively identified the person in the photograph as Watson.

Id. at 10-11; see also id. at 11 (asserting that “Taylor was by no means

certain whether the photographs he was shown by the police on December

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Com. v. Watson, N., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-watson-n-pasuperct-2025.