Com. v. Williams, M.

• Court: Superior Court of Pennsylvania
• Decided: February 12, 2026
• Docket: 594 EDA 2025
• Status: Unpublished
• Author: Sullivan

Opinion

J-S39034-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : MICHAEL CRANDLE WILLIAMS : : Appellant : No. 594 EDA 2025

Appeal from the Judgment of Sentence Entered October 15, 2024 In the Court of Common Pleas of Lehigh County Criminal Division at No(s): CP-39-CR-0004392-2023

BEFORE: STABILE, J., NICHOLS, J., and SULLIVAN, J.

MEMORANDUM BY SULLIVAN, J.: FILED FEBRUARY 12, 2026

Michael Crandle Williams (“Williams”) appeals pro se from the judgment

of sentence for his convictions of evading arrest or detention on foot and

disorderly conduct.1 Having determined Williams’s claims are waived,

meritless, and/or premature, we affirm.

The factual and procedural history is as follows:

In October 2023, the Allentown Police Department responded to a report

that Williams, who had multiple active warrants from Schuylkill County, was

at 1822 Greenleaf Street. As the officers set up a perimeter, they saw Williams

run out of the front door of the house, cross the street, jump a fence, and run

into the backyard. When the officers went to that house, they saw an elderly

woman run out and heard her say Williams was there. See Trial Court

Opinion, 5/22/25, at 1-2. ____________________________________________

1 See 18 Pa.C.S.A. §§ 5104.2(a), (b)(3), 5503(a)(4). J-S39034-25

Officer David Lawrence (“Officer Lawrence”) entered the house and

announced his presence. Williams was not inside. The officers searched for

Williams by car and located Williams on Cedar Street. Officer Lawrence

commanded Williams to stop. Williams continued to flee, ignoring the officers’

commands. See Trial Court Opinion, 5/22/25, at 2.

Williams eventually stopped in a side yard of a residence, and “got into

. . . an aggressive fighting stance.” N.T., 8/20/24, at 50. Officer Lawrence

initiated a “chase stun” with a taser. Id. at 50-51. After a struggle, Officer

Lawrence handcuffed Williams.2

At his formal arraignment in February 2024, Williams told the court he

wanted to proceed pro se. The trial court appointed standby counsel who later

filed a motion to withdraw her appearance. Counsel stated in the motion that

Williams knew he would not receive new counsel and would proceed pro se.

See Motion to Withdraw Appearance, 8/16/24, unnumbered at 3. Counsel

was permitted to withdraw the day before jury selection, and Williams

proceeded pro se. See N.T., 8/19/24, at 9-25.

In August 2024, a jury found Williams guilty of the above offenses. At

the sentencing hearing in October 2024, the court reviewed a presentence

report (“PSI”) which showed Williams was on state parole when he committed

the offenses and had prior convictions for violent crimes. The court imposed

____________________________________________

2 At trial, the Commonwealth presented the video from Officer Lawrence’s body camera.

-2- J-S39034-25

an aggregate sentence of twelve to twenty-four months of imprisonment. See

Trial Court Opinion, 5/22/25, at 3.

Williams filed a post-sentence motion which was denied by operation of

law. This timely appeal followed.3

Williams raises the following issues for our review:

1. Whether the court erred in denying [Williams’s] right to counsel during trial and sentencing[?]

2. Whether the court erred in denying [Williams’s] writ of subpoena and exculpatory evidence[?]

3. Whether the court erred in denying [Williams’s] writ of habeas corpus and motion to suppress the unlawful bench warrant for failure to appear out of Schuylkill County for lack of subject matter jurisdiction[?]

4. Whether the Commonwealth presented sufficient evidence to convict [Williams] of evading arrest or detention on foot and disorderly conduct[?]

5. Whether the court erred in denying [Williams’s] claims and motion for ineffective assistance of counsel[?]

6. Whether the court erred in denying [Williams’s] motion for judgment of acquittal at the end of the Commonwealth[’s] case[?]

Williams’s Brief at 6 (unnecessary capitalization omitted, italics added).

Williams first claims the trial court erred in denying his right to counsel

during trial and sentencing. See Williams’s Brief at 10-13.

3 Williams repeatedly appealed this matter prematurely. We discuss only his timely appeal.

-3- J-S39034-25

We initially consider whether Williams preserved his claim for appellate

review. In this regard, we have stated, “Rule 1925(b) is a crucial component

of the appellate process because it allows the trial court to identify and focus

on those issues the parties plan to raise on appeal.” Commonwealth v.

Snyder, 316 A.3d 178, 181 (Pa. Super. 2024) (internal quotation marks and

citation omitted). An issue not raised in the 1925(b) statement is deemed

waived for appellate review. See Commonwealth v. Bonnett, 239 A.3d

1096, 1106 (Pa. Super. 2020); see also Pa.R.A.P. 1925(b)(4)(vii); Pa.R.A.P.

302(a) (stating issues may not be raised for the first time on appeal).

Additionally, a Rule 1925(b) statement must be sufficiently “concise and

coherent such that the trial judge may be able to identify the issues raised on

appeal[.]” Commonwealth v. Vurimindi, 200 A.3d 1031, 1038 (Pa. Super.

2018) (internal quotation marks and citation omitted). Although Williams is

proceeding pro se, he is subject to the same rules of procedure as defendants

who are represented by counsel. See Commonwealth v. Williams, 896

A.2d 523, 574 (Pa. 2006).

Williams waived his right to counsel claim by failing to include it in his

Rule 1925(b) statement. Williams does not use the phrase “right to counsel”

or anything that would specifically indicate such a claim in his statement.

Although he mentions a “Sixth Amendment [v]iolation,” he fails to elaborate

on it. See Williams’s 1925(b) Statement at 6. Because Williams’s 1925(b)

statement was not sufficiently concise and coherent such that the trial judge

-4- J-S39034-25

could identify the issues raised on appeal, this claim is waived. See

Vurimindi, 200 A.3d at 1038.

Williams next claims the trial court erred in denying his writ of subpoena

and motion to compel exculpatory evidence. See Williams’s Brief at 13-22.

Williams asserts the trial court denied him a fair trial and the outcome of trial

would have been different if he was able to present testimony to refute Officer

Lawrence. See id. at 15.4 He further asserts he was arrested only because

of a 911 call to police, and the transcript of that call was exculpatory evidence.

See id. at 17.

We review a trial court’s decision to quash a subpoena for an abuse of

discretion. See Commonwealth v. Walsh, 36 A.3d 613, 620 (Pa. Super.

2021); see also Commonwealth v. Cherry, No. 1011 MDA 2020, 2021 WL

5177853 (non-precedential memorandum at *13) (Pa. Super. Nov. 8, 2021).5

This Court has observed that:

under both our state and federal constitutions, a criminal defendant has a right of compulsory process to obtain witnesses in his favor. The right to compulsory process encompasses the right to meet the prosecution’s case with the aid of witnesses, and the right to elicit the aid of the Commonwealth in securing those ____________________________________________

4 Williams does not name the witnesses he wished to subpoena in his argument. Elsewhere in his brief, he identifies them as Officer Daniel Miller of the Allentown Police Department and Sargeant Tyler Fleming of the Schuylkill Haven County Police Department. See Williams’s Brief at 38, 42; Williams’s Writ of Subpoena, 8/8/24, at 1.

5 See Pa.R.A.P. 126(b) (unpublished non-precedential memoranda decision of

Superior Court filed after May 1, 2019, may be cited for persuasive value).

-5- J-S39034-25

witnesses at trial, both of which are fundamental to a fair trial. Just as an accused has the right to confront the prosecution’s witnesses for the purpose of challenging their testimony, he has the right to present his own witnesses to establish a defense. This right is a fundamental element of due process of law. The constitutional right, though fundamental, is not, however, absolute. In order to compel the attendance of a witness at trial, it must be shown that the information possessed by the witness is material, i.e., capable of affecting the outcome of the trial, and that it is favorable to the defense.

Commonwealth v. McKenzie, 581 A.2d 655, 657 (Pa. Super. 1990)

(quotation marks, internal citations, and alterations omitted, emphasis

added).

The trial court noted:

[t]he . . . claims of “[j]udicial [e]rrors,” . . . lack specificity, preventing this court from meaningfully addressing them, and should be considered waived. One of his claims refers to Brady materials and claims he was denied access to those materials[] but fails to explain how this Court denied him access to any discovery.

Trial Court Opinion, 5/22/25, at 10 (alterations added). Williams has failed to

show how the witnesses he wished to subpoena, whom he does not even name

in his discussion of this claim, were capable of affecting the outcome of the

trial in a manner favorable to the defense. See Commonwealth v. Banks,

946 A.2d 721, 724 (Pa. Super. 2008). Williams does not state what testimony

they would have given. Instead, Williams offers only boilerplate assertions

that “[h]ad [he] been given said right to call witnesses, the outcome of the

trial would have been different . . . because [he] would have been able to

present testimony and evidence that would have refuted and/or contradicted

the Commonwealth’s only witness[.]” See Williams’s Brief at 15.

-6- J-S39034-25

Williams failed to explain how the trial court denied him access to the

allegedly exculpatory witnesses. In his 1925(b) statement, Williams does not

identify how the court interfered with discovery. See Vurimindi, 200 A.3d at

1038. Further, regarding alleged exculpatory evidence, the Commonwealth

showed Williams all of the body camera footage, and the trial court denied

Williams’s motion to sanction the Commonwealth for failing to produce

discovery. See N.T., 8/19/24, at 7-9. Absent identifying information, it is

unclear what material Williams claims was withheld. Thus, Williams’s

exculpatory evidence claim is waived and/or meritless.

With regard to his claim the trial court should not have quashed the

subpoena, Williams entirely fails to account for the fact he had an active bench

warrant from Schuylkill County. See Exhibit 2; see also Commonwealth v.

Smith, 234 A.3d 576, 585 (Pa. 2020) (explaining “a bench warrant issues

only when an individual does not appear when required[] and thus acts to

elude or evade law enforcement or prosecution.”). Thus, there was a valid

warrant for Williams’s arrest and the trial court did not abuse its discretion in

quashing the subpoena.

In his third claim, Williams asserts the court lacked subject matter

jurisdiction. See Williams’s Brief at 22-30. However, it is not clear exactly

why he argues the court lacked jurisdiction. To the extent that we can

determine his argument, it is meritless.

Preliminarily, Williams’s argument is patently incorrect. A municipal

police officer in Pennsylvania has the power to enforce the laws of this

-7- J-S39034-25

Commonwealth and can arrest an individual pursuant to a bench warrant

issued in another county. See 42 Pa.C.S.A. § 8953(a)(1). Thus, the police

had the authority to arrest Williams. Additionally, the Rules of Criminal

Procedure clearly contemplate out-of-county action on bench warrants.

Pursuant to Pa.R.Crim.P. 150(A)(4), “[w]hen the individual is arrested outside

the county of issuance [of a bench warrant], the authority in charge of the

county jail promptly shall notify the proper authorities in the county of

issuance that the individual is being held pursuant to the bench warrant.”

Williams does not point to anything which would demonstrate that “the

authority in charge of the county jail” did not comply with this rule.

Furthermore, Williams was arrested in Lehigh County, for his actions in

Lehigh County, and went to court in Lehigh County on those charges—not

on the Schuylkill County bench warrant; thus, his jurisdiction argument under

any interpretation is frivolous.

In his fourth claim, Williams avers the Commonwealth failed to present

sufficient evidence to convict him of evading arrest or detention on foot and

disorderly conduct. See Williams’s Brief at 30-37.

To preserve a sufficiency claim, an appellant’s Rule 1925(b) statement

“must specify the element or elements upon which the evidence was

insufficient.” Commonwealth v. Widger, 237 A.3d 1151, 1156 (Pa. Super.

2020). If the appellant does not specify such elements, the sufficiency claim

is deemed waived. Commonwealth v. Roche, 153 A.3d 1063, 1072 (Pa.

Super. 2017).

-8- J-S39034-25

In his Rule 1925(b) statement, Williams presented a boilerplate

challenge to his convictions and failed to specify which conviction he was

challenging, which elements of the crime he was challenging, or explain why

the evidence was insufficient. See Williams’s Rule 1925(b) Statement at 5-6

(stating “the jury rendered [an] improper verdict of guilt.”). The trial court

interpreted these assertions to implicate the sufficiency of the evidence;

however, this does not void waiver. See Trial Court Opinion at 6-7;

Commonwealth v. Heggins, 809 A.2d 908, 911 (Pa. Super. 2002)

(explaining “[e]ven if the trial court correctly guesses the issues [a]ppellant

raises on appeal and writes an opinion pursuant to that supposition, the issue

is still waived.”). Williams’s Rule 1925(b) statement was so vague that he

waived his sufficiency claim. See Commonwealth v. Hale, No. 1476 WDA

2024, 2025 WL 2838817 (non-precedential memorandum at *1) (Pa. Super.

Oct. 7, 2025) (finding sufficiency claim waived because 1925(b) statement

was vague and did not specify the elements challenged or why the evidence

was insufficient). Because we conclude Williams waived his challenge to the

sufficiency of the evidence, we do not address the merits of his claim.

In his fifth claim, Williams asserts the court erred in denying his motion

asserting the ineffective assistance of counsel. See Williams’s Brief at 37-44.

His claim is premature.

Claims of trial counsel’s ineffectiveness are to be raised in collateral

proceedings and may not be raised on direct appeal. See Commonwealth

v. Bradley, 261 A.3d 381, 391 (Pa. 2021) (stating “claims of trial counsel's

-9- J-S39034-25

ineffectiveness . . . are to be presented in a [petition filed pursuant to the Post

Conviction Relief Act (“PCRA”), 42 Pa.C.S.A. §§ 9541-9546]”); see also

Commonwealth v. Holmes, 79 A.3d 562, 576 (Pa. 2013) (stating that

absent particular, narrow exceptions, “claims of ineffective assistance of

counsel are to be deferred to PCRA review”); 42 Pa.C.S.A. § 9543(a)(2)(ii)

(setting forth ineffective assistance of counsel as grounds for collateral relief

if pleaded and proven by a preponderance of the evidence). Therefore,

Williams’s claims of ineffective assistance of trial counsel are premature, and

we dismiss them without prejudice to his right to raise them in a collateral

proceeding. See Commonwealth v. Royal, 312 A.3d 317, 323 (Pa. Super.

2024).

In his final claim, Williams asserts the court erred in denying his motion

for judgment of acquittal “without conducting adequate findings on the

merits.” See Williams’s Brief at 44-48.

An issue that is not raised in the Rule 1925(b) statement with specificity

is deemed waived. See Bonnett, 239 A.3d at 1106; Vurimindi, 200 A.3d at

1038; see also Pa.R.A.P. 1925(b)(4)(vii). Williams’s Rule 1925(b) statement

asserts the court erred in its “denial and refusal to make adequate findings on

the merits of [Williams’s p]re-trial and [p]ost-trial motions.” Williams’s

1925(b) Statement at 3. Williams filed or attempted to file at least fifteen

motions during the pre-trial-through-post-trial period. The trial court was

unable to meaningfully address his claim without clarification as to, at

minimum, which motions were at issue and/or what the claims were. See

- 10 - J-S39034-25

Commonwealth v. Dowling, 778 A.2d 683, 686-87 (Pa. Super. 2001)

(explaining when a Rule 1925(b) statement “is too vague to allow the court

to identify the issues raised on appeal[, it] is the functional equivalent to no

. . . [s]tatement at all.”).6 Thus, Williams’s sixth claim is waived.

For the reasons discussed above, we find Williams’s claims are either

waived, meritless, or premature. Accordingly, we affirm the judgment of

sentence.

Judgment of sentence affirmed.

Date: 2/12/2026

6 Williams filed his motion for judgment of acquittal prematurely, before the

commencement of trial. See Order Denying Motion for Acquittal, 8/20/24; Pa.R.Crim.P. 704(B)(1); see also Commonwealth v. Wilson, 227 A.3d 928, 937 (Pa. Super. 2020) (emphasis added) (explaining, pursuant to the Rules of Criminal Procedure, “[u]nder extraordinary circumstances, when the interests of justice require, the trial judge may, before sentencing, hear an oral motion in arrest of judgment, for a judgment of acquittal, or for a new trial.”).

- 11 - J-S39034-25

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : MICHAEL CRANDLE WILLIAMS : : Appellant : No. 594 EDA 2025

Appeal from the Judgment of Sentence Entered October 15, 2024 In the Court of Common Pleas of Lehigh County Criminal Division at No(s): CP-39-CR-0004392-2023

Michael Crandle Williams (“Williams”) appeals pro se from the judgment

of sentence for his convictions of evading arrest or detention on foot and

disorderly conduct.1 Having determined Williams’s claims are waived,

In October 2023, the Allentown Police Department responded to a report

that Williams, who had multiple active warrants from Schuylkill County, was

at 1822 Greenleaf Street. As the officers set up a perimeter, they saw Williams

run out of the front door of the house, cross the street, jump a fence, and run

into the backyard. When the officers went to that house, they saw an elderly

woman run out and heard her say Williams was there. See Trial Court

Opinion, 5/22/25, at 1-2. ____________________________________________

1 See 18 Pa.C.S.A. §§ 5104.2(a), (b)(3), 5503(a)(4). J-S39034-25

Officer David Lawrence (“Officer Lawrence”) entered the house and

announced his presence. Williams was not inside. The officers searched for

Williams by car and located Williams on Cedar Street. Officer Lawrence

commanded Williams to stop. Williams continued to flee, ignoring the officers’

Williams eventually stopped in a side yard of a residence, and “got into

. . . an aggressive fighting stance.” N.T., 8/20/24, at 50. Officer Lawrence

initiated a “chase stun” with a taser. Id. at 50-51. After a struggle, Officer

At his formal arraignment in February 2024, Williams told the court he

wanted to proceed pro se. The trial court appointed standby counsel who later

filed a motion to withdraw her appearance. Counsel stated in the motion that

Williams knew he would not receive new counsel and would proceed pro se.

See Motion to Withdraw Appearance, 8/16/24, unnumbered at 3. Counsel

was permitted to withdraw the day before jury selection, and Williams

In August 2024, a jury found Williams guilty of the above offenses. At

the sentencing hearing in October 2024, the court reviewed a presentence

report (“PSI”) which showed Williams was on state parole when he committed

the offenses and had prior convictions for violent crimes. The court imposed

2 At trial, the Commonwealth presented the video from Officer Lawrence’s body camera.

an aggregate sentence of twelve to twenty-four months of imprisonment. See

Williams filed a post-sentence motion which was denied by operation of

1. Whether the court erred in denying [Williams’s] right to counsel during trial and sentencing[?]

2. Whether the court erred in denying [Williams’s] writ of subpoena and exculpatory evidence[?]

3. Whether the court erred in denying [Williams’s] writ of habeas corpus and motion to suppress the unlawful bench warrant for failure to appear out of Schuylkill County for lack of subject matter jurisdiction[?]

4. Whether the Commonwealth presented sufficient evidence to convict [Williams] of evading arrest or detention on foot and disorderly conduct[?]

5. Whether the court erred in denying [Williams’s] claims and motion for ineffective assistance of counsel[?]

6. Whether the court erred in denying [Williams’s] motion for judgment of acquittal at the end of the Commonwealth[’s] case[?]

Williams’s Brief at 6 (unnecessary capitalization omitted, italics added).

Williams first claims the trial court erred in denying his right to counsel

3 Williams repeatedly appealed this matter prematurely. We discuss only his timely appeal.

We initially consider whether Williams preserved his claim for appellate

review. In this regard, we have stated, “Rule 1925(b) is a crucial component

of the appellate process because it allows the trial court to identify and focus

on those issues the parties plan to raise on appeal.” Commonwealth v.

Snyder, 316 A.3d 178, 181 (Pa. Super. 2024) (internal quotation marks and

citation omitted). An issue not raised in the 1925(b) statement is deemed

waived for appellate review. See Commonwealth v. Bonnett, 239 A.3d

1096, 1106 (Pa. Super. 2020); see also Pa.R.A.P. 1925(b)(4)(vii); Pa.R.A.P.

302(a) (stating issues may not be raised for the first time on appeal).

Additionally, a Rule 1925(b) statement must be sufficiently “concise and

coherent such that the trial judge may be able to identify the issues raised on

appeal[.]” Commonwealth v. Vurimindi, 200 A.3d 1031, 1038 (Pa. Super.

2018) (internal quotation marks and citation omitted). Although Williams is

proceeding pro se, he is subject to the same rules of procedure as defendants

who are represented by counsel. See Commonwealth v. Williams, 896

Williams waived his right to counsel claim by failing to include it in his

Rule 1925(b) statement. Williams does not use the phrase “right to counsel”

or anything that would specifically indicate such a claim in his statement.

Although he mentions a “Sixth Amendment [v]iolation,” he fails to elaborate

on it. See Williams’s 1925(b) Statement at 6. Because Williams’s 1925(b)

statement was not sufficiently concise and coherent such that the trial judge

could identify the issues raised on appeal, this claim is waived. See

Williams next claims the trial court erred in denying his writ of subpoena

and motion to compel exculpatory evidence. See Williams’s Brief at 13-22.

Williams asserts the trial court denied him a fair trial and the outcome of trial

would have been different if he was able to present testimony to refute Officer

Lawrence. See id. at 15.4 He further asserts he was arrested only because

of a 911 call to police, and the transcript of that call was exculpatory evidence.

We review a trial court’s decision to quash a subpoena for an abuse of

discretion. See Commonwealth v. Walsh, 36 A.3d 613, 620 (Pa. Super.

2021); see also Commonwealth v. Cherry, No. 1011 MDA 2020, 2021 WL

5177853 (non-precedential memorandum at *13) (Pa. Super. Nov. 8, 2021).5

under both our state and federal constitutions, a criminal defendant has a right of compulsory process to obtain witnesses in his favor. The right to compulsory process encompasses the right to meet the prosecution’s case with the aid of witnesses, and the right to elicit the aid of the Commonwealth in securing those ____________________________________________

4 Williams does not name the witnesses he wished to subpoena in his argument. Elsewhere in his brief, he identifies them as Officer Daniel Miller of the Allentown Police Department and Sargeant Tyler Fleming of the Schuylkill Haven County Police Department. See Williams’s Brief at 38, 42; Williams’s Writ of Subpoena, 8/8/24, at 1.

5 See Pa.R.A.P. 126(b) (unpublished non-precedential memoranda decision of

Superior Court filed after May 1, 2019, may be cited for persuasive value).

witnesses at trial, both of which are fundamental to a fair trial. Just as an accused has the right to confront the prosecution’s witnesses for the purpose of challenging their testimony, he has the right to present his own witnesses to establish a defense. This right is a fundamental element of due process of law. The constitutional right, though fundamental, is not, however, absolute. In order to compel the attendance of a witness at trial, it must be shown that the information possessed by the witness is material, i.e., capable of affecting the outcome of the trial, and that it is favorable to the defense.

Commonwealth v. McKenzie, 581 A.2d 655, 657 (Pa. Super. 1990)

(quotation marks, internal citations, and alterations omitted, emphasis

[t]he . . . claims of “[j]udicial [e]rrors,” . . . lack specificity, preventing this court from meaningfully addressing them, and should be considered waived. One of his claims refers to Brady materials and claims he was denied access to those materials[] but fails to explain how this Court denied him access to any discovery.

Trial Court Opinion, 5/22/25, at 10 (alterations added). Williams has failed to

show how the witnesses he wished to subpoena, whom he does not even name

in his discussion of this claim, were capable of affecting the outcome of the

trial in a manner favorable to the defense. See Commonwealth v. Banks,

946 A.2d 721, 724 (Pa. Super. 2008). Williams does not state what testimony

they would have given. Instead, Williams offers only boilerplate assertions

that “[h]ad [he] been given said right to call witnesses, the outcome of the

trial would have been different . . . because [he] would have been able to

present testimony and evidence that would have refuted and/or contradicted

the Commonwealth’s only witness[.]” See Williams’s Brief at 15.

Williams failed to explain how the trial court denied him access to the

allegedly exculpatory witnesses. In his 1925(b) statement, Williams does not

identify how the court interfered with discovery. See Vurimindi, 200 A.3d at

1038. Further, regarding alleged exculpatory evidence, the Commonwealth

showed Williams all of the body camera footage, and the trial court denied

Williams’s motion to sanction the Commonwealth for failing to produce

discovery. See N.T., 8/19/24, at 7-9. Absent identifying information, it is

unclear what material Williams claims was withheld. Thus, Williams’s

With regard to his claim the trial court should not have quashed the

subpoena, Williams entirely fails to account for the fact he had an active bench

warrant from Schuylkill County. See Exhibit 2; see also Commonwealth v.

Smith, 234 A.3d 576, 585 (Pa. 2020) (explaining “a bench warrant issues

only when an individual does not appear when required[] and thus acts to

elude or evade law enforcement or prosecution.”). Thus, there was a valid

warrant for Williams’s arrest and the trial court did not abuse its discretion in

In his third claim, Williams asserts the court lacked subject matter

jurisdiction. See Williams’s Brief at 22-30. However, it is not clear exactly

why he argues the court lacked jurisdiction. To the extent that we can

Preliminarily, Williams’s argument is patently incorrect. A municipal

police officer in Pennsylvania has the power to enforce the laws of this

Commonwealth and can arrest an individual pursuant to a bench warrant

issued in another county. See 42 Pa.C.S.A. § 8953(a)(1). Thus, the police

had the authority to arrest Williams. Additionally, the Rules of Criminal

Procedure clearly contemplate out-of-county action on bench warrants.

Pursuant to Pa.R.Crim.P. 150(A)(4), “[w]hen the individual is arrested outside

the county of issuance [of a bench warrant], the authority in charge of the

county jail promptly shall notify the proper authorities in the county of

issuance that the individual is being held pursuant to the bench warrant.”

Williams does not point to anything which would demonstrate that “the

authority in charge of the county jail” did not comply with this rule.

Furthermore, Williams was arrested in Lehigh County, for his actions in

Lehigh County, and went to court in Lehigh County on those charges—not

on the Schuylkill County bench warrant; thus, his jurisdiction argument under

In his fourth claim, Williams avers the Commonwealth failed to present

sufficient evidence to convict him of evading arrest or detention on foot and

To preserve a sufficiency claim, an appellant’s Rule 1925(b) statement

“must specify the element or elements upon which the evidence was

insufficient.” Commonwealth v. Widger, 237 A.3d 1151, 1156 (Pa. Super.

2020). If the appellant does not specify such elements, the sufficiency claim

is deemed waived. Commonwealth v. Roche, 153 A.3d 1063, 1072 (Pa.

In his Rule 1925(b) statement, Williams presented a boilerplate

challenge to his convictions and failed to specify which conviction he was

challenging, which elements of the crime he was challenging, or explain why

the evidence was insufficient. See Williams’s Rule 1925(b) Statement at 5-6

(stating “the jury rendered [an] improper verdict of guilt.”). The trial court

interpreted these assertions to implicate the sufficiency of the evidence;

however, this does not void waiver. See Trial Court Opinion at 6-7;

(explaining “[e]ven if the trial court correctly guesses the issues [a]ppellant

raises on appeal and writes an opinion pursuant to that supposition, the issue

is still waived.”). Williams’s Rule 1925(b) statement was so vague that he

waived his sufficiency claim. See Commonwealth v. Hale, No. 1476 WDA

2024, 2025 WL 2838817 (non-precedential memorandum at *1) (Pa. Super.

Oct. 7, 2025) (finding sufficiency claim waived because 1925(b) statement

was vague and did not specify the elements challenged or why the evidence

was insufficient). Because we conclude Williams waived his challenge to the

sufficiency of the evidence, we do not address the merits of his claim.

In his fifth claim, Williams asserts the court erred in denying his motion

asserting the ineffective assistance of counsel. See Williams’s Brief at 37-44.

Claims of trial counsel’s ineffectiveness are to be raised in collateral

proceedings and may not be raised on direct appeal. See Commonwealth

v. Bradley, 261 A.3d 381, 391 (Pa. 2021) (stating “claims of trial counsel's

ineffectiveness . . . are to be presented in a [petition filed pursuant to the Post

Conviction Relief Act (“PCRA”), 42 Pa.C.S.A. §§ 9541-9546]”); see also

Commonwealth v. Holmes, 79 A.3d 562, 576 (Pa. 2013) (stating that

absent particular, narrow exceptions, “claims of ineffective assistance of

counsel are to be deferred to PCRA review”); 42 Pa.C.S.A. § 9543(a)(2)(ii)

(setting forth ineffective assistance of counsel as grounds for collateral relief

if pleaded and proven by a preponderance of the evidence). Therefore,

Williams’s claims of ineffective assistance of trial counsel are premature, and

we dismiss them without prejudice to his right to raise them in a collateral

proceeding. See Commonwealth v. Royal, 312 A.3d 317, 323 (Pa. Super.

In his final claim, Williams asserts the court erred in denying his motion

for judgment of acquittal “without conducting adequate findings on the

An issue that is not raised in the Rule 1925(b) statement with specificity

is deemed waived. See Bonnett, 239 A.3d at 1106; Vurimindi, 200 A.3d at

1038; see also Pa.R.A.P. 1925(b)(4)(vii). Williams’s Rule 1925(b) statement

asserts the court erred in its “denial and refusal to make adequate findings on

the merits of [Williams’s p]re-trial and [p]ost-trial motions.” Williams’s

1925(b) Statement at 3. Williams filed or attempted to file at least fifteen

motions during the pre-trial-through-post-trial period. The trial court was

unable to meaningfully address his claim without clarification as to, at

minimum, which motions were at issue and/or what the claims were. See

Commonwealth v. Dowling, 778 A.2d 683, 686-87 (Pa. Super. 2001)

(explaining when a Rule 1925(b) statement “is too vague to allow the court

to identify the issues raised on appeal[, it] is the functional equivalent to no

. . . [s]tatement at all.”).6 Thus, Williams’s sixth claim is waived.

For the reasons discussed above, we find Williams’s claims are either

waived, meritless, or premature. Accordingly, we affirm the judgment of

6 Williams filed his motion for judgment of acquittal prematurely, before the

commencement of trial. See Order Denying Motion for Acquittal, 8/20/24; Pa.R.Crim.P. 704(B)(1); see also Commonwealth v. Wilson, 227 A.3d 928, 937 (Pa. Super. 2020) (emphasis added) (explaining, pursuant to the Rules of Criminal Procedure, “[u]nder extraordinary circumstances, when the interests of justice require, the trial judge may, before sentencing, hear an oral motion in arrest of judgment, for a judgment of acquittal, or for a new trial.”).

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : MICHAEL CRANDLE WILLIAMS : : Appellant : No. 594 EDA 2025

Appeal from the Judgment of Sentence Entered October 15, 2024 In the Court of Common Pleas of Lehigh County Criminal Division at No(s): CP-39-CR-0004392-2023

Michael Crandle Williams (“Williams”) appeals pro se from the judgment

of sentence for his convictions of evading arrest or detention on foot and

disorderly conduct.1 Having determined Williams’s claims are waived,

In October 2023, the Allentown Police Department responded to a report

that Williams, who had multiple active warrants from Schuylkill County, was

at 1822 Greenleaf Street. As the officers set up a perimeter, they saw Williams

run out of the front door of the house, cross the street, jump a fence, and run

into the backyard. When the officers went to that house, they saw an elderly

woman run out and heard her say Williams was there. See Trial Court

Opinion, 5/22/25, at 1-2. ____________________________________________

1 See 18 Pa.C.S.A. §§ 5104.2(a), (b)(3), 5503(a)(4). J-S39034-25

Officer David Lawrence (“Officer Lawrence”) entered the house and

announced his presence. Williams was not inside. The officers searched for

Williams by car and located Williams on Cedar Street. Officer Lawrence

commanded Williams to stop. Williams continued to flee, ignoring the officers’

Williams eventually stopped in a side yard of a residence, and “got into

. . . an aggressive fighting stance.” N.T., 8/20/24, at 50. Officer Lawrence

initiated a “chase stun” with a taser. Id. at 50-51. After a struggle, Officer

At his formal arraignment in February 2024, Williams told the court he

wanted to proceed pro se. The trial court appointed standby counsel who later

filed a motion to withdraw her appearance. Counsel stated in the motion that

Williams knew he would not receive new counsel and would proceed pro se.

See Motion to Withdraw Appearance, 8/16/24, unnumbered at 3. Counsel

was permitted to withdraw the day before jury selection, and Williams

In August 2024, a jury found Williams guilty of the above offenses. At

the sentencing hearing in October 2024, the court reviewed a presentence

report (“PSI”) which showed Williams was on state parole when he committed

the offenses and had prior convictions for violent crimes. The court imposed

2 At trial, the Commonwealth presented the video from Officer Lawrence’s body camera.

an aggregate sentence of twelve to twenty-four months of imprisonment. See

Williams filed a post-sentence motion which was denied by operation of

1. Whether the court erred in denying [Williams’s] right to counsel during trial and sentencing[?]

2. Whether the court erred in denying [Williams’s] writ of subpoena and exculpatory evidence[?]

3. Whether the court erred in denying [Williams’s] writ of habeas corpus and motion to suppress the unlawful bench warrant for failure to appear out of Schuylkill County for lack of subject matter jurisdiction[?]

4. Whether the Commonwealth presented sufficient evidence to convict [Williams] of evading arrest or detention on foot and disorderly conduct[?]

5. Whether the court erred in denying [Williams’s] claims and motion for ineffective assistance of counsel[?]

6. Whether the court erred in denying [Williams’s] motion for judgment of acquittal at the end of the Commonwealth[’s] case[?]

Williams’s Brief at 6 (unnecessary capitalization omitted, italics added).

Williams first claims the trial court erred in denying his right to counsel

3 Williams repeatedly appealed this matter prematurely. We discuss only his timely appeal.

We initially consider whether Williams preserved his claim for appellate

review. In this regard, we have stated, “Rule 1925(b) is a crucial component

of the appellate process because it allows the trial court to identify and focus

on those issues the parties plan to raise on appeal.” Commonwealth v.

Snyder, 316 A.3d 178, 181 (Pa. Super. 2024) (internal quotation marks and

citation omitted). An issue not raised in the 1925(b) statement is deemed

waived for appellate review. See Commonwealth v. Bonnett, 239 A.3d

1096, 1106 (Pa. Super. 2020); see also Pa.R.A.P. 1925(b)(4)(vii); Pa.R.A.P.

302(a) (stating issues may not be raised for the first time on appeal).

Additionally, a Rule 1925(b) statement must be sufficiently “concise and

coherent such that the trial judge may be able to identify the issues raised on

appeal[.]” Commonwealth v. Vurimindi, 200 A.3d 1031, 1038 (Pa. Super.

2018) (internal quotation marks and citation omitted). Although Williams is

proceeding pro se, he is subject to the same rules of procedure as defendants

who are represented by counsel. See Commonwealth v. Williams, 896

Williams waived his right to counsel claim by failing to include it in his

Rule 1925(b) statement. Williams does not use the phrase “right to counsel”

or anything that would specifically indicate such a claim in his statement.

Although he mentions a “Sixth Amendment [v]iolation,” he fails to elaborate

on it. See Williams’s 1925(b) Statement at 6. Because Williams’s 1925(b)

statement was not sufficiently concise and coherent such that the trial judge

could identify the issues raised on appeal, this claim is waived. See

Williams next claims the trial court erred in denying his writ of subpoena

and motion to compel exculpatory evidence. See Williams’s Brief at 13-22.

Williams asserts the trial court denied him a fair trial and the outcome of trial

would have been different if he was able to present testimony to refute Officer

Lawrence. See id. at 15.4 He further asserts he was arrested only because

of a 911 call to police, and the transcript of that call was exculpatory evidence.

We review a trial court’s decision to quash a subpoena for an abuse of

discretion. See Commonwealth v. Walsh, 36 A.3d 613, 620 (Pa. Super.

2021); see also Commonwealth v. Cherry, No. 1011 MDA 2020, 2021 WL

5177853 (non-precedential memorandum at *13) (Pa. Super. Nov. 8, 2021).5

under both our state and federal constitutions, a criminal defendant has a right of compulsory process to obtain witnesses in his favor. The right to compulsory process encompasses the right to meet the prosecution’s case with the aid of witnesses, and the right to elicit the aid of the Commonwealth in securing those ____________________________________________

4 Williams does not name the witnesses he wished to subpoena in his argument. Elsewhere in his brief, he identifies them as Officer Daniel Miller of the Allentown Police Department and Sargeant Tyler Fleming of the Schuylkill Haven County Police Department. See Williams’s Brief at 38, 42; Williams’s Writ of Subpoena, 8/8/24, at 1.

5 See Pa.R.A.P. 126(b) (unpublished non-precedential memoranda decision of

Superior Court filed after May 1, 2019, may be cited for persuasive value).

witnesses at trial, both of which are fundamental to a fair trial. Just as an accused has the right to confront the prosecution’s witnesses for the purpose of challenging their testimony, he has the right to present his own witnesses to establish a defense. This right is a fundamental element of due process of law. The constitutional right, though fundamental, is not, however, absolute. In order to compel the attendance of a witness at trial, it must be shown that the information possessed by the witness is material, i.e., capable of affecting the outcome of the trial, and that it is favorable to the defense.

Commonwealth v. McKenzie, 581 A.2d 655, 657 (Pa. Super. 1990)

(quotation marks, internal citations, and alterations omitted, emphasis

[t]he . . . claims of “[j]udicial [e]rrors,” . . . lack specificity, preventing this court from meaningfully addressing them, and should be considered waived. One of his claims refers to Brady materials and claims he was denied access to those materials[] but fails to explain how this Court denied him access to any discovery.

Trial Court Opinion, 5/22/25, at 10 (alterations added). Williams has failed to

show how the witnesses he wished to subpoena, whom he does not even name

in his discussion of this claim, were capable of affecting the outcome of the

trial in a manner favorable to the defense. See Commonwealth v. Banks,

946 A.2d 721, 724 (Pa. Super. 2008). Williams does not state what testimony

they would have given. Instead, Williams offers only boilerplate assertions

that “[h]ad [he] been given said right to call witnesses, the outcome of the

trial would have been different . . . because [he] would have been able to

present testimony and evidence that would have refuted and/or contradicted

the Commonwealth’s only witness[.]” See Williams’s Brief at 15.

Williams failed to explain how the trial court denied him access to the

allegedly exculpatory witnesses. In his 1925(b) statement, Williams does not

identify how the court interfered with discovery. See Vurimindi, 200 A.3d at

1038. Further, regarding alleged exculpatory evidence, the Commonwealth

showed Williams all of the body camera footage, and the trial court denied

Williams’s motion to sanction the Commonwealth for failing to produce

discovery. See N.T., 8/19/24, at 7-9. Absent identifying information, it is

unclear what material Williams claims was withheld. Thus, Williams’s

With regard to his claim the trial court should not have quashed the

subpoena, Williams entirely fails to account for the fact he had an active bench

warrant from Schuylkill County. See Exhibit 2; see also Commonwealth v.

Smith, 234 A.3d 576, 585 (Pa. 2020) (explaining “a bench warrant issues

only when an individual does not appear when required[] and thus acts to

elude or evade law enforcement or prosecution.”). Thus, there was a valid

warrant for Williams’s arrest and the trial court did not abuse its discretion in

In his third claim, Williams asserts the court lacked subject matter

jurisdiction. See Williams’s Brief at 22-30. However, it is not clear exactly

why he argues the court lacked jurisdiction. To the extent that we can

Preliminarily, Williams’s argument is patently incorrect. A municipal

police officer in Pennsylvania has the power to enforce the laws of this

Commonwealth and can arrest an individual pursuant to a bench warrant

issued in another county. See 42 Pa.C.S.A. § 8953(a)(1). Thus, the police

had the authority to arrest Williams. Additionally, the Rules of Criminal

Procedure clearly contemplate out-of-county action on bench warrants.

Pursuant to Pa.R.Crim.P. 150(A)(4), “[w]hen the individual is arrested outside

the county of issuance [of a bench warrant], the authority in charge of the

county jail promptly shall notify the proper authorities in the county of

issuance that the individual is being held pursuant to the bench warrant.”

Williams does not point to anything which would demonstrate that “the

authority in charge of the county jail” did not comply with this rule.

Furthermore, Williams was arrested in Lehigh County, for his actions in

Lehigh County, and went to court in Lehigh County on those charges—not

on the Schuylkill County bench warrant; thus, his jurisdiction argument under

In his fourth claim, Williams avers the Commonwealth failed to present

sufficient evidence to convict him of evading arrest or detention on foot and

To preserve a sufficiency claim, an appellant’s Rule 1925(b) statement

“must specify the element or elements upon which the evidence was

insufficient.” Commonwealth v. Widger, 237 A.3d 1151, 1156 (Pa. Super.

2020). If the appellant does not specify such elements, the sufficiency claim

is deemed waived. Commonwealth v. Roche, 153 A.3d 1063, 1072 (Pa.

In his Rule 1925(b) statement, Williams presented a boilerplate

challenge to his convictions and failed to specify which conviction he was

challenging, which elements of the crime he was challenging, or explain why

the evidence was insufficient. See Williams’s Rule 1925(b) Statement at 5-6

(stating “the jury rendered [an] improper verdict of guilt.”). The trial court

interpreted these assertions to implicate the sufficiency of the evidence;

however, this does not void waiver. See Trial Court Opinion at 6-7;

(explaining “[e]ven if the trial court correctly guesses the issues [a]ppellant

raises on appeal and writes an opinion pursuant to that supposition, the issue

is still waived.”). Williams’s Rule 1925(b) statement was so vague that he

waived his sufficiency claim. See Commonwealth v. Hale, No. 1476 WDA

2024, 2025 WL 2838817 (non-precedential memorandum at *1) (Pa. Super.

Oct. 7, 2025) (finding sufficiency claim waived because 1925(b) statement

was vague and did not specify the elements challenged or why the evidence

was insufficient). Because we conclude Williams waived his challenge to the

sufficiency of the evidence, we do not address the merits of his claim.

In his fifth claim, Williams asserts the court erred in denying his motion

asserting the ineffective assistance of counsel. See Williams’s Brief at 37-44.

Claims of trial counsel’s ineffectiveness are to be raised in collateral

proceedings and may not be raised on direct appeal. See Commonwealth

v. Bradley, 261 A.3d 381, 391 (Pa. 2021) (stating “claims of trial counsel's

ineffectiveness . . . are to be presented in a [petition filed pursuant to the Post

Conviction Relief Act (“PCRA”), 42 Pa.C.S.A. §§ 9541-9546]”); see also

Commonwealth v. Holmes, 79 A.3d 562, 576 (Pa. 2013) (stating that

absent particular, narrow exceptions, “claims of ineffective assistance of

counsel are to be deferred to PCRA review”); 42 Pa.C.S.A. § 9543(a)(2)(ii)

(setting forth ineffective assistance of counsel as grounds for collateral relief

if pleaded and proven by a preponderance of the evidence). Therefore,

Williams’s claims of ineffective assistance of trial counsel are premature, and

we dismiss them without prejudice to his right to raise them in a collateral

proceeding. See Commonwealth v. Royal, 312 A.3d 317, 323 (Pa. Super.

In his final claim, Williams asserts the court erred in denying his motion

for judgment of acquittal “without conducting adequate findings on the

An issue that is not raised in the Rule 1925(b) statement with specificity

is deemed waived. See Bonnett, 239 A.3d at 1106; Vurimindi, 200 A.3d at

1038; see also Pa.R.A.P. 1925(b)(4)(vii). Williams’s Rule 1925(b) statement

asserts the court erred in its “denial and refusal to make adequate findings on

the merits of [Williams’s p]re-trial and [p]ost-trial motions.” Williams’s

1925(b) Statement at 3. Williams filed or attempted to file at least fifteen

motions during the pre-trial-through-post-trial period. The trial court was

unable to meaningfully address his claim without clarification as to, at

minimum, which motions were at issue and/or what the claims were. See

Commonwealth v. Dowling, 778 A.2d 683, 686-87 (Pa. Super. 2001)

(explaining when a Rule 1925(b) statement “is too vague to allow the court

to identify the issues raised on appeal[, it] is the functional equivalent to no

. . . [s]tatement at all.”).6 Thus, Williams’s sixth claim is waived.

For the reasons discussed above, we find Williams’s claims are either

waived, meritless, or premature. Accordingly, we affirm the judgment of

6 Williams filed his motion for judgment of acquittal prematurely, before the

commencement of trial. See Order Denying Motion for Acquittal, 8/20/24; Pa.R.Crim.P. 704(B)(1); see also Commonwealth v. Wilson, 227 A.3d 928, 937 (Pa. Super. 2020) (emphasis added) (explaining, pursuant to the Rules of Criminal Procedure, “[u]nder extraordinary circumstances, when the interests of justice require, the trial judge may, before sentencing, hear an oral motion in arrest of judgment, for a judgment of acquittal, or for a new trial.”).

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : MICHAEL CRANDLE WILLIAMS : : Appellant : No. 594 EDA 2025

Appeal from the Judgment of Sentence Entered October 15, 2024 In the Court of Common Pleas of Lehigh County Criminal Division at No(s): CP-39-CR-0004392-2023

Michael Crandle Williams (“Williams”) appeals pro se from the judgment

of sentence for his convictions of evading arrest or detention on foot and

disorderly conduct.1 Having determined Williams’s claims are waived,

In October 2023, the Allentown Police Department responded to a report

that Williams, who had multiple active warrants from Schuylkill County, was

at 1822 Greenleaf Street. As the officers set up a perimeter, they saw Williams

run out of the front door of the house, cross the street, jump a fence, and run

into the backyard. When the officers went to that house, they saw an elderly

woman run out and heard her say Williams was there. See Trial Court

Opinion, 5/22/25, at 1-2. ____________________________________________

1 See 18 Pa.C.S.A. §§ 5104.2(a), (b)(3), 5503(a)(4). J-S39034-25

Officer David Lawrence (“Officer Lawrence”) entered the house and

announced his presence. Williams was not inside. The officers searched for

Williams by car and located Williams on Cedar Street. Officer Lawrence

commanded Williams to stop. Williams continued to flee, ignoring the officers’

Williams eventually stopped in a side yard of a residence, and “got into

. . . an aggressive fighting stance.” N.T., 8/20/24, at 50. Officer Lawrence

initiated a “chase stun” with a taser. Id. at 50-51. After a struggle, Officer

At his formal arraignment in February 2024, Williams told the court he

wanted to proceed pro se. The trial court appointed standby counsel who later

filed a motion to withdraw her appearance. Counsel stated in the motion that

Williams knew he would not receive new counsel and would proceed pro se.

See Motion to Withdraw Appearance, 8/16/24, unnumbered at 3. Counsel

was permitted to withdraw the day before jury selection, and Williams

In August 2024, a jury found Williams guilty of the above offenses. At

the sentencing hearing in October 2024, the court reviewed a presentence

report (“PSI”) which showed Williams was on state parole when he committed

the offenses and had prior convictions for violent crimes. The court imposed

2 At trial, the Commonwealth presented the video from Officer Lawrence’s body camera.

an aggregate sentence of twelve to twenty-four months of imprisonment. See

Williams filed a post-sentence motion which was denied by operation of

1. Whether the court erred in denying [Williams’s] right to counsel during trial and sentencing[?]

2. Whether the court erred in denying [Williams’s] writ of subpoena and exculpatory evidence[?]

3. Whether the court erred in denying [Williams’s] writ of habeas corpus and motion to suppress the unlawful bench warrant for failure to appear out of Schuylkill County for lack of subject matter jurisdiction[?]

4. Whether the Commonwealth presented sufficient evidence to convict [Williams] of evading arrest or detention on foot and disorderly conduct[?]

5. Whether the court erred in denying [Williams’s] claims and motion for ineffective assistance of counsel[?]

6. Whether the court erred in denying [Williams’s] motion for judgment of acquittal at the end of the Commonwealth[’s] case[?]

Williams’s Brief at 6 (unnecessary capitalization omitted, italics added).

Williams first claims the trial court erred in denying his right to counsel

3 Williams repeatedly appealed this matter prematurely. We discuss only his timely appeal.

We initially consider whether Williams preserved his claim for appellate

review. In this regard, we have stated, “Rule 1925(b) is a crucial component

of the appellate process because it allows the trial court to identify and focus

on those issues the parties plan to raise on appeal.” Commonwealth v.

Snyder, 316 A.3d 178, 181 (Pa. Super. 2024) (internal quotation marks and

citation omitted). An issue not raised in the 1925(b) statement is deemed

waived for appellate review. See Commonwealth v. Bonnett, 239 A.3d

1096, 1106 (Pa. Super. 2020); see also Pa.R.A.P. 1925(b)(4)(vii); Pa.R.A.P.

302(a) (stating issues may not be raised for the first time on appeal).

Additionally, a Rule 1925(b) statement must be sufficiently “concise and

coherent such that the trial judge may be able to identify the issues raised on

appeal[.]” Commonwealth v. Vurimindi, 200 A.3d 1031, 1038 (Pa. Super.

2018) (internal quotation marks and citation omitted). Although Williams is

proceeding pro se, he is subject to the same rules of procedure as defendants

who are represented by counsel. See Commonwealth v. Williams, 896

Williams waived his right to counsel claim by failing to include it in his

Rule 1925(b) statement. Williams does not use the phrase “right to counsel”

or anything that would specifically indicate such a claim in his statement.

Although he mentions a “Sixth Amendment [v]iolation,” he fails to elaborate

on it. See Williams’s 1925(b) Statement at 6. Because Williams’s 1925(b)

statement was not sufficiently concise and coherent such that the trial judge

could identify the issues raised on appeal, this claim is waived. See

Williams next claims the trial court erred in denying his writ of subpoena

and motion to compel exculpatory evidence. See Williams’s Brief at 13-22.

Williams asserts the trial court denied him a fair trial and the outcome of trial

would have been different if he was able to present testimony to refute Officer

Lawrence. See id. at 15.4 He further asserts he was arrested only because

of a 911 call to police, and the transcript of that call was exculpatory evidence.

We review a trial court’s decision to quash a subpoena for an abuse of

discretion. See Commonwealth v. Walsh, 36 A.3d 613, 620 (Pa. Super.

2021); see also Commonwealth v. Cherry, No. 1011 MDA 2020, 2021 WL

5177853 (non-precedential memorandum at *13) (Pa. Super. Nov. 8, 2021).5

under both our state and federal constitutions, a criminal defendant has a right of compulsory process to obtain witnesses in his favor. The right to compulsory process encompasses the right to meet the prosecution’s case with the aid of witnesses, and the right to elicit the aid of the Commonwealth in securing those ____________________________________________

4 Williams does not name the witnesses he wished to subpoena in his argument. Elsewhere in his brief, he identifies them as Officer Daniel Miller of the Allentown Police Department and Sargeant Tyler Fleming of the Schuylkill Haven County Police Department. See Williams’s Brief at 38, 42; Williams’s Writ of Subpoena, 8/8/24, at 1.

5 See Pa.R.A.P. 126(b) (unpublished non-precedential memoranda decision of

Superior Court filed after May 1, 2019, may be cited for persuasive value).

witnesses at trial, both of which are fundamental to a fair trial. Just as an accused has the right to confront the prosecution’s witnesses for the purpose of challenging their testimony, he has the right to present his own witnesses to establish a defense. This right is a fundamental element of due process of law. The constitutional right, though fundamental, is not, however, absolute. In order to compel the attendance of a witness at trial, it must be shown that the information possessed by the witness is material, i.e., capable of affecting the outcome of the trial, and that it is favorable to the defense.

Commonwealth v. McKenzie, 581 A.2d 655, 657 (Pa. Super. 1990)

(quotation marks, internal citations, and alterations omitted, emphasis

[t]he . . . claims of “[j]udicial [e]rrors,” . . . lack specificity, preventing this court from meaningfully addressing them, and should be considered waived. One of his claims refers to Brady materials and claims he was denied access to those materials[] but fails to explain how this Court denied him access to any discovery.

Trial Court Opinion, 5/22/25, at 10 (alterations added). Williams has failed to

show how the witnesses he wished to subpoena, whom he does not even name

in his discussion of this claim, were capable of affecting the outcome of the

trial in a manner favorable to the defense. See Commonwealth v. Banks,

946 A.2d 721, 724 (Pa. Super. 2008). Williams does not state what testimony

they would have given. Instead, Williams offers only boilerplate assertions

that “[h]ad [he] been given said right to call witnesses, the outcome of the

trial would have been different . . . because [he] would have been able to

present testimony and evidence that would have refuted and/or contradicted

the Commonwealth’s only witness[.]” See Williams’s Brief at 15.

Williams failed to explain how the trial court denied him access to the

allegedly exculpatory witnesses. In his 1925(b) statement, Williams does not

identify how the court interfered with discovery. See Vurimindi, 200 A.3d at

1038. Further, regarding alleged exculpatory evidence, the Commonwealth

showed Williams all of the body camera footage, and the trial court denied

Williams’s motion to sanction the Commonwealth for failing to produce

discovery. See N.T., 8/19/24, at 7-9. Absent identifying information, it is

unclear what material Williams claims was withheld. Thus, Williams’s

With regard to his claim the trial court should not have quashed the

subpoena, Williams entirely fails to account for the fact he had an active bench

warrant from Schuylkill County. See Exhibit 2; see also Commonwealth v.

Smith, 234 A.3d 576, 585 (Pa. 2020) (explaining “a bench warrant issues

only when an individual does not appear when required[] and thus acts to

elude or evade law enforcement or prosecution.”). Thus, there was a valid

warrant for Williams’s arrest and the trial court did not abuse its discretion in

In his third claim, Williams asserts the court lacked subject matter

jurisdiction. See Williams’s Brief at 22-30. However, it is not clear exactly

why he argues the court lacked jurisdiction. To the extent that we can

Preliminarily, Williams’s argument is patently incorrect. A municipal

police officer in Pennsylvania has the power to enforce the laws of this

Commonwealth and can arrest an individual pursuant to a bench warrant

issued in another county. See 42 Pa.C.S.A. § 8953(a)(1). Thus, the police

had the authority to arrest Williams. Additionally, the Rules of Criminal

Procedure clearly contemplate out-of-county action on bench warrants.

Pursuant to Pa.R.Crim.P. 150(A)(4), “[w]hen the individual is arrested outside

the county of issuance [of a bench warrant], the authority in charge of the

county jail promptly shall notify the proper authorities in the county of

issuance that the individual is being held pursuant to the bench warrant.”

Williams does not point to anything which would demonstrate that “the

authority in charge of the county jail” did not comply with this rule.

Furthermore, Williams was arrested in Lehigh County, for his actions in

Lehigh County, and went to court in Lehigh County on those charges—not

on the Schuylkill County bench warrant; thus, his jurisdiction argument under

In his fourth claim, Williams avers the Commonwealth failed to present

sufficient evidence to convict him of evading arrest or detention on foot and

To preserve a sufficiency claim, an appellant’s Rule 1925(b) statement

“must specify the element or elements upon which the evidence was

insufficient.” Commonwealth v. Widger, 237 A.3d 1151, 1156 (Pa. Super.

2020). If the appellant does not specify such elements, the sufficiency claim

is deemed waived. Commonwealth v. Roche, 153 A.3d 1063, 1072 (Pa.

In his Rule 1925(b) statement, Williams presented a boilerplate

challenge to his convictions and failed to specify which conviction he was

challenging, which elements of the crime he was challenging, or explain why

the evidence was insufficient. See Williams’s Rule 1925(b) Statement at 5-6

(stating “the jury rendered [an] improper verdict of guilt.”). The trial court

interpreted these assertions to implicate the sufficiency of the evidence;

however, this does not void waiver. See Trial Court Opinion at 6-7;

(explaining “[e]ven if the trial court correctly guesses the issues [a]ppellant

raises on appeal and writes an opinion pursuant to that supposition, the issue

is still waived.”). Williams’s Rule 1925(b) statement was so vague that he

waived his sufficiency claim. See Commonwealth v. Hale, No. 1476 WDA

2024, 2025 WL 2838817 (non-precedential memorandum at *1) (Pa. Super.

Oct. 7, 2025) (finding sufficiency claim waived because 1925(b) statement

was vague and did not specify the elements challenged or why the evidence

was insufficient). Because we conclude Williams waived his challenge to the

sufficiency of the evidence, we do not address the merits of his claim.

In his fifth claim, Williams asserts the court erred in denying his motion

asserting the ineffective assistance of counsel. See Williams’s Brief at 37-44.

Claims of trial counsel’s ineffectiveness are to be raised in collateral

proceedings and may not be raised on direct appeal. See Commonwealth

v. Bradley, 261 A.3d 381, 391 (Pa. 2021) (stating “claims of trial counsel's

ineffectiveness . . . are to be presented in a [petition filed pursuant to the Post

Conviction Relief Act (“PCRA”), 42 Pa.C.S.A. §§ 9541-9546]”); see also

Commonwealth v. Holmes, 79 A.3d 562, 576 (Pa. 2013) (stating that

absent particular, narrow exceptions, “claims of ineffective assistance of

counsel are to be deferred to PCRA review”); 42 Pa.C.S.A. § 9543(a)(2)(ii)

(setting forth ineffective assistance of counsel as grounds for collateral relief

if pleaded and proven by a preponderance of the evidence). Therefore,

Williams’s claims of ineffective assistance of trial counsel are premature, and

we dismiss them without prejudice to his right to raise them in a collateral

proceeding. See Commonwealth v. Royal, 312 A.3d 317, 323 (Pa. Super.

In his final claim, Williams asserts the court erred in denying his motion

for judgment of acquittal “without conducting adequate findings on the

An issue that is not raised in the Rule 1925(b) statement with specificity

is deemed waived. See Bonnett, 239 A.3d at 1106; Vurimindi, 200 A.3d at

1038; see also Pa.R.A.P. 1925(b)(4)(vii). Williams’s Rule 1925(b) statement

asserts the court erred in its “denial and refusal to make adequate findings on

the merits of [Williams’s p]re-trial and [p]ost-trial motions.” Williams’s

1925(b) Statement at 3. Williams filed or attempted to file at least fifteen

motions during the pre-trial-through-post-trial period. The trial court was

unable to meaningfully address his claim without clarification as to, at

minimum, which motions were at issue and/or what the claims were. See

Commonwealth v. Dowling, 778 A.2d 683, 686-87 (Pa. Super. 2001)

(explaining when a Rule 1925(b) statement “is too vague to allow the court

to identify the issues raised on appeal[, it] is the functional equivalent to no

. . . [s]tatement at all.”).6 Thus, Williams’s sixth claim is waived.

For the reasons discussed above, we find Williams’s claims are either

waived, meritless, or premature. Accordingly, we affirm the judgment of

6 Williams filed his motion for judgment of acquittal prematurely, before the

commencement of trial. See Order Denying Motion for Acquittal, 8/20/24; Pa.R.Crim.P. 704(B)(1); see also Commonwealth v. Wilson, 227 A.3d 928, 937 (Pa. Super. 2020) (emphasis added) (explaining, pursuant to the Rules of Criminal Procedure, “[u]nder extraordinary circumstances, when the interests of justice require, the trial judge may, before sentencing, hear an oral motion in arrest of judgment, for a judgment of acquittal, or for a new trial.”).

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