Commonwealth v. Lyles

17 Pa. D. & C.5th 37
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedOctober 7, 2010
Docketno. 42 of 2010
StatusPublished

This text of 17 Pa. D. & C.5th 37 (Commonwealth v. Lyles) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Lyles, 17 Pa. D. & C.5th 37 (Pa. Super. Ct. 2010).

Opinion

COX, J.,

— Before the court for disposition is the petition for writ of habeas corpus filed on behalf of the defendant Kevin Robert Lyles, which argues that the commonwealth has failed to present sufficient evidence to establish that the defendant was in possession of marijuana.

On May 29, 2009, Patrolman Ronald L. Williams of the New Castle Police Department received a call from off-duty police officer James Paglia, informing Patrolman Williams that the defendant, who had approximately nine outstanding bench warrants and state parole detainers, was observed in the passenger seat of a maroon Ford Explorer in the area of Beer 4 Less, which is located in New Castle, Lawrence County, Pennsylvania. Patrolman Williams located the Explorer and activated his lights while traveling on West Washington Street, which is in the vicinity of Beer 4 Less. At that time, a female, who was driving, began to stop the vehicle; however, before the vehicle stopped completely, the defendant exited the same and ran through the Beer 4 Less parking lot toward Body Structure Fitness. Patrolman Williams pursued the defendant who made a sudden right-hand turn, which caused him to strike the police officer’s vehicle. Officer Paglia was also approaching the defendant from the other end of the parking lot. Eventually, the defendant was apprehended, searched and no contraband was found on [39]*39his person. The police officers also searched between the vehicles and discovered a cellular phone and a bag of marijuana in close proximity to each other. The defendant admitted that the cellular phone belonged to him, but denied ownership of the marijuana. It must be noted that neither of the police officers observed the defendant drop the cellular phone or the bag of marijuana.

The defendant was arrested and charged with a violation of 35 P.S. § 780-113(a)(31), which prohibits possession of a small amount of marijuana. A preliminary hearing was held before Magisterial District Judge Scott A. McGrath on January 13,2009, and the charge was bound over to this court. Now, the defendant contends that the commonwealth did not present sufficient evidence to establish that he was in possession of the bag of marijuana discovered in close proximity to his cellular phone.

Where a criminal defendant seeks to challenge the sufficiency of the evidence presented at his preliminary hearing, he may do so by filing a writ of habeas corpus. Commonwealth v. McBride, 528 Pa. 153, 595 A.2d 589 (1995). The purpose of a preliminary hearing is to avoid the incarceration or trial of a defendant unless there is sufficient evidence to establish a crime was committed and the probability the defendant could be connected with the crime. Commonwealth v. Fox, 422 Pa. Super. 224, 234, 619 A.2d 327, 332 (1993). In a pre-trial habeas corpus proceeding, as in a preliminary hearing, the commonwealth has the burden of establishing a prima facie case, offering some proof to establish each material element of the offense as charged. Commonwealth v. Owens, 397 Pa. Super. 507, 580 A.2d 412 (1990). This does not mean that the prosecution must prove the accused guilty beyond a [40]*40reasonable doubt, but rather, the prosecution must establish sufficient probable cause that the accused has committed the offense. Commonwealth v. Prosdocimo, 331 Pa. Super, 51, 479 A.2d 1073 (1994).

The standard in determining whether a defendant is properly held for court is: (a) that the record reveals a prima facie showing that a crime or crimes have been committed; and (b) that the defendant was in some way legally responsible. Liciaga v. Court of Common Pleas of Lehigh County, 523 Pa. 258, 263, 566 A.2d 246, 248 (1989). A prima facie case consists of evidence, read in the light most favorable to the commonwealth, that sufficiently establishes both the commission of a crime and that the accused is probably the perpetrator of that crime. Commonwealth v. Fountain, 811 A.2d 24 (Pa. Super. 2002). The commonwealth establishes a prima facie case when it produces evidence that, if accepted as true, would warrant the trial judge to allow the case to go to a jury. Commonwealth v. Marti, 779 A.2d 1177, 1180 (1995). The commonwealth need not prove the elements of the crime beyond a reasonable doubt. Id. The prima facie case merely requires evidence of the existence of each element of the crime charged. Id. Additionally, the evidence is to be reviewed in a light most favorable to the commonwealth and the commonwealth is entitled to reasonable inferences drawn from the evidence. Id.

The weight and credibility of the evidence is not a factor at this stage, the commonwealth need only demonstrate sufficient probable cause to believe the person charged has committed the offense. Id. As a result of the commonwealth bearing the minor burden of establishing a prima facie case, a witness’ credibility is not an issue at a preliminary [41]*41hearing. Fox, supra. The committing magistrate is precluded from considering the credibility of a witness who is called upon to testify during the preliminary hearing. Liciaga, supra, (citing Commonwealth v. Wojdak, 502 Pa. 359, 466 A.2d 991 (1983); Commonwealth v. Hampton, 462 Pa. 322, 341 A.2d 101 (1975)). Neither is it for the court ruling on the petition for writ of habeas corpus to assess the credibility of the witnesses presented at the preliminary hearing. Commonwealth v. Carmody, 799 A.2d 143 (Pa. Super. 2002).

The defendant contends that the commonwealth failed to establish that he was in possession of the marijuana; thus, it has not established the charge of possession of a small amount of marijuana. 35 P.S. § 780-113(a)(31) states:

(a) The following acts and the causing thereof within the commonwealth are hereby prohibited:
(31) Notwithstanding other subsections of this section, (i) the possession of a small amount of marijuana only for personal use; (ii) the possession of a small amount marijuana with the intent to distribute it but not to sell it; or (iii) the distribution of a small amount marijuana but not for sale.
For purposes of this subsection, thirty (30) grams of marihuana or eight (8) grams of hashish shall be considered a small amount of marijuana.

In cases where the contraband is not found on the defendant’s person, the commonwealth may establish that the defendant had constructive possession over the contraband. Commonwealth v. Haskins, 450 Pa. Super. 540, 544, 677 A.2d 328, 330 (1996) (citing Commonwealth v. [42]

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Related

Commonwealth v. Carmody
799 A.2d 143 (Superior Court of Pennsylvania, 2002)
Commonwealth v. Owen
580 A.2d 412 (Supreme Court of Pennsylvania, 1990)
Commonwealth v. Hampton
341 A.2d 101 (Supreme Court of Pennsylvania, 1975)
Commonwealth v. Marti
779 A.2d 1177 (Superior Court of Pennsylvania, 2001)
Commonwealth v. Wojdak
466 A.2d 991 (Supreme Court of Pennsylvania, 1983)
Liciaga v. Court of Common Pleas
566 A.2d 246 (Supreme Court of Pennsylvania, 1989)
Commonwealth v. MacOlino
469 A.2d 132 (Supreme Court of Pennsylvania, 1983)
Commonwealth v. Haskins
677 A.2d 328 (Superior Court of Pennsylvania, 1996)
Commonwealth v. McBride
595 A.2d 589 (Supreme Court of Pennsylvania, 1991)
Commonwealth v. Clark
746 A.2d 1128 (Superior Court of Pennsylvania, 2000)
Commonwealth v. Thompson
428 A.2d 223 (Superior Court of Pennsylvania, 1981)
Commonwealth v. Fox
619 A.2d 327 (Superior Court of Pennsylvania, 1993)
Commonwealth v. Kirkland
831 A.2d 607 (Superior Court of Pennsylvania, 2003)
Commonwealth v. Fountain
811 A.2d 24 (Superior Court of Pennsylvania, 2002)
Commonwealth v. Valette
613 A.2d 548 (Supreme Court of Pennsylvania, 1992)
Commonwealth v. Prosdocimo
479 A.2d 1073 (Supreme Court of Pennsylvania, 1984)

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Bluebook (online)
17 Pa. D. & C.5th 37, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-lyles-pactcompllawren-2010.