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Commonwealth v. Wilkerson

  • ammcphee03
  • Mar 2
  • 2 min read

Statutory Interpretation

Sufficiency of the Evidence

Philosophical Notes


Statutory Interpretation

  • a trial court’s findings of fact are owed the highest degree of appellate deference

  • findings of fact are only overturned when plainly wrong or without evidence

  • the question is whether any trier of fact could have found sufficient evidence beyond a reasonable doubt

  • the evidence may have been interpreted another way, but upon review, facts must be interpreted in a light favorable to the Commonwealth

    • the Commonwealth must receive the benefit of all reasonable inferences deducible from the evidence



Sufficiency of the Evidence

  • proof is evidence sufficient to allow a rational factfinder to conclude beyond a reasonable doubt that the defendant intentionally and consciously possessed the contraband with knowledge of its nature and character

  • constructive possession can be proven by solely circumstantial evidence

  • a circumstantial fact is admitted on the basis of an inference when the inference is a probable explanation of another fact and a more probable and natural one than other explanations, if any

  • there was no “ambiguous” circumstantial evidence that is equally consistent with both Wilkerson’s guilt and Wilkerson’s hypothesis of innocence

  • trial court was within discretion to deny defendant’s motion to strike for insufficient evidence of knowledge of possession of controlled substance, an element of the crime for which defendant was charged

  • deference owed to trial court’s finding knowledge of possession, including constructive possession because

    • 1. the substance was found in the defendant’s bag,

    • 2. the defendant asserted no one could access his bag, and

    • 3. defendant asserted that he checked his bag every 15 minutes


Philosophical Notes

  • This opinion kicked off an interesting conversation with ChatGPT on sufficiency of the evidence and Hume’s epistemology



 
 
 

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