Com. v. Watts, S.

CourtSuperior Court of Pennsylvania
DecidedMay 8, 2026
Docket2428 EDA 2024
StatusUnpublished
AuthorMurray

This text of Com. v. Watts, S. (Com. v. Watts, S.) 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. Watts, S., (Pa. Ct. App. 2026).

Opinion

J-S17001-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : SHAWN J. WATTS : : Appellant : No. 2428 EDA 2024

Appeal from the Judgment of Sentence Entered August 23, 2024 In the Court of Common Pleas of Philadelphia County Criminal Division at No(s): CP-51-CR-0007258-2023

BEFORE: MURRAY, J., McLAUGHLIN, J., and KING, J.

MEMORANDUM BY MURRAY, J.: FILED MAY 8, 2026

Shawn J. Watts (Appellant) appeals from the judgment of sentence

imposed following his non-jury convictions of two counts each of simple

assault, recklessly endangering another person (REAP), and driving under the

influence (DUI) – general impairment;1 and one count each of aggravated

assault, aggravated assault by vehicle while DUI, and careless driving. 2 We

affirm in part and reverse in part, vacate the judgment of sentence, and

remand for resentencing.

The trial court summarized the relevant factual history as follows:

On or about September 15, 2023, around 8:10 p.m., [] Shanik Baxter exited the IGA Supermarket on the corner of Wayne Avenue and Chelten Avenue in the City of Philadelphia. Ms. Baxter ____________________________________________

1 18 Pa.C.S.A. §§ 2701(a), 2705; 75 Pa.C.S.A. § 3802(a)(1).

2 18 Pa.C.S.A. § 2702(a)(1); 75 Pa.C.S.A. §§ 3735.1(a), 3714(a). J-S17001-25

was walking with her sister, Annie, and cousin[,] A.H.[,] and his unnamed brother. As the group crossed Wayne Avenue, Ms. Baxter heard the screech of car tires and jumped back, grabbing A.H. Ms. Baxter then heard the continuous revving of an engine as she tossed A.H. out of the way. As she tossed A.H., [Appellant’s] vehicle struck [Ms. Baxter] and knocked her to the ground.

Approximately eight minutes after the accident, several bystanders surrounded Ms. Baxter and helped her out of the street. [Appellant] … attempted to flee the scene in his vehicle, a silver Chevy Impala. [Appellant] belligerently yelled that “it was only an accident” and that he didn’t understand why everybody was “so upset.” Ms. Baxter at that time was unable to stand up due to [] pain in her left leg. Approximately eight [] people assisted Ms. Baxter following the accident. [Ms. Baxter] was then transported to Einstein Hospital and later transferred to Temple Hospital, where she was diagnosed with a broken kneecap. A.H. was transported to Saint Christopher’s Hospital[,] where he was treated for scrapes from his head to his leg.

Several bystanders contacted the Philadelphia Police Department (“PPD”) to report the incident. PPD Officers Stacy Little and Timothy Camlin responded to multiple radio calls about the accident. Upon the [officers’] arrival to the scene, Officer Little observed [Appellant] attempt[] to push [damaged] pieces of his vehicle back together. [Appellant] attempted to push his loose front-end bumper back onto the car. Officer Little also observed a partially empty tequila bottle in the backseat of [Appellant’s] vehicle. Officer Camlin and other officers noted the odor of alcohol. The bystanders then informed Officer Camlin that [Appellant] was operating the vehicle that struck Ms. Baxter and A.H. [Appellant] was placed under arrest and transported to the hospital.

PPD Officer Joseph DiGangi interviewed [Appellant] at the hospital. [Appellant] was handcuffed to the bed and read his DL- 26B PennDOT [implied consent] warnings. [Appellant] was acting belligerently, being loud and aggressive. [Appellant] refused to sign the DL-26B and continuously yelled over Officer DiGangi’s reading of the warnings.

-2- J-S17001-25

Trial Court Opinion, 12/10/24, at 1-3 (record citations omitted; some

capitalization and punctuation modified).

Following a bench trial on June 6, 2024, the trial court convicted

Appellant of the above-described offenses. The trial court deferred sentencing

and ordered the preparation of a presentence investigation report (PSI). On

August 23, 2024, the trial court sentenced Appellant, for his aggravated

assault conviction, to 5 to 10 years’ imprisonment, followed by 3 years’

probation. For his aggravated assault by vehicle while DUI conviction, the

trial court imposed 10 years of probation, to run concurrently with his

aggravated assault sentence. For the remaining convictions, the trial court

entered a finding of guilt without further penalty. Appellant filed a timely post-

sentence motion, which the trial court denied.

This timely appeal followed. Appellant and the trial court have complied

with Pa.R.A.P. 1925.3

____________________________________________

3 Appellant’s prior counsel, George S. Yacoubian, Jr., Esquire (Attorney Yacoubian), filed in this Court an Anders brief on December 14, 2024, and a petition to withdraw from representation two days later. See Anders v. California, 386 U.S. 738 (1967). On June 6, 2025, we denied Attorney Yacoubian’s petition to withdraw, as his Anders brief was substantially deficient. See Commonwealth v. Watts, 343 A.3d 198, 2428 EDA 2024 (Pa. Super. 2025) (unpublished memorandum at 4-6) (noting that Attorney Yacoubian failed to refer to anything in the record that could arguably support the appeal, and essentially argued against Appellant’s interest). We therefore directed Attorney Yacoubian to file a proper Anders brief or an advocate’s brief. See id. (unpublished memorandum at 6). Attorney Yacoubian subsequently filed a new Anders brief, which remained substantively deficient. Accordingly, we vacated Attorney Yacoubian’s appointment and (Footnote Continued Next Page)

-3- J-S17001-25

On appeal, Appellant raises the following issues for review:

A. Whether the evidence was insufficient to sustain [Appellant’s] convictions for aggravated assault, aggravated assault by vehicle while DUI, DUI, simple assault, and [REAP], where the Commonwealth failed to prove the requisite mens rea beyond a reasonable doubt[?]

B. Whether the trial court abused its discretion in denying [Appellant’s] post-sentence motion[,] where the verdicts for aggravated assault, aggravated assault by vehicle while DUI, DUI, simple assault, and [REAP] were against the weight of the evidence[?]

C. Whether the sentencing court abused its discretion by imposing an aggregate sentence of five to ten years’ incarceration[,] where the sentence was unnecessarily harsh and excessive in relation to the gravity of the offenses and failed to adequately consider [Appellant’s] rehabilitative needs and the fundamental purposes of sentencing[?]

Appellant’s Brief at 4-5 (issues reordered).

In his first claim, Appellant challenges the sufficiency of the evidence

supporting his convictions.4 See id. at 17-24.

A sufficiency challenge “is a question of law, for which our standard of

review is de novo and our scope of review is plenary.” Commonwealth v.

Packer, 168 A.3d 161, 166 (Pa. 2017). When we review a challenge to the

sufficiency of the evidence,

remanded the case to the trial court for appointment of new counsel. See Order, 8/5/25. The trial court appointed Jessica C. Mann, Esquire, who filed an advocate’s brief on Appellant’s behalf.

4 Appellant does not challenge his careless driving conviction.

-4- J-S17001-25

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Bluebook (online)
Com. v. Watts, S., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-watts-s-pasuperct-2026.