Commonwealth v. Hobel
Decision Date | 10 May 2022 |
Docket Number | 822 WDA 2021, No. 823 WDA 2021, No. 824 WDA 2021, No. 825 WDA 2021 |
Citation | 275 A.3d 1049 |
Parties | COMMONWEALTH of Pennsylvania v. Shawn A. HOBEL, Appellant Commonwealth of Pennsylvania v. Shawn Aaron Hobel, Appellant Commonwealth of Pennsylvania v. Shawn Aaron Hobel, Appellant Commonwealth of Pennsylvania v. Shawn Aaron Hobel, Appellant |
Court | Pennsylvania Superior Court |
Christopher P. Lacich, Youngstown, OH, for appellant.
Jennifer A. Buck, Office of the Attorney General, Harrisburg, for Commonwealth, appellee.
Gregory J. Simatic, Office of the Attorney General, Pittsburgh, for Commonwealth, appellee.
In these consolidated appeals, Shawn Aaron Hobel (Hobel) appeals from the judgment of sentence of 20 to 40 years imposed by the Court of Common Pleas of Lawrence County (trial court) after a jury convicted him of robbing three convenience stores and various offenses related to a high-speed chase with the police. On appeal, he raises four challenges. First, he challenges the denial of his suppression motion in which he alleged that the extraterritorial actions of the police in the chase violated the Municipal Police Jurisdiction Act (MPJA), 42 Pa.C.S. §§ 8951 - 8954. Second, he challenges the joinder of his cases for trial. Third, he challenges the sufficiency of the evidence for the robberies because none of the clerks identified him at trial. Finally, he challenges the weight of the evidence for his convictions. We affirm.
Over a 40-hour period in December 2016, a man wearing a gray hoodie and a black mask robbed three convenience stores in Lawrence County with what looked like a black handgun. None of the clerks could identify the robber but the clerk in the last robbery saw the robber get into a dark-colored sedan. As a result, New Castle Police put out a "be on the lookout" (BOLO) to area police departments for the sedan. A few hours later, Officer Michael Lynch (Officer Lynch) of the Shenango Township Police was patrolling when he saw a sedan matching the BOLO. While following the sedan into neighboring Slippery Rock Township, Officer Lynch saw another car parked in the woods; at the time, Hobel was in the car doing drugs with his friend, Elissa Heemer (Heemer). When he saw Officer Lynch turn around, Hobel fled. After going through a stop sign, Hobel sped away swerving across the road. Officer Lynch activated his emergency lights but Hobel would not pull over as he led police on a high-speed chase spanning multiple municipalities and police departments. The chase eventually ended when Corporal James Hoyland (Corporal Hoyland) of the New Castle Police blocked off Hobel's car. With no escape possible, Hobel held a gun to Heemer's head and threatened to kill her. When Hobel disregarded several warnings, Corporal Hoyland shot him six times, following which he was taken to a hospital and survived.
At the scene, Heemer told police that Hobel admitted to her in the car that he had committed several robberies. The police then obtained a search warrant for Hobel's car and found several items connecting him to the robberies: a gray hoodie; a black airsoft gun; black masks; and a pack of cigarettes of the same brand asked for by the robber during one of the robberies. In the meantime, police also recovered Hobel's shoes because they resembled those worn by the robber.
Police filed four complaints against Hobel—three for the robberies and one for the chase. Before trial, Hobel moved to suppress the items recovered, arguing both Officer Lynch and Corporal Hoyland acted extraterritorially in violation of the MPJA. After two hearings, the trial court denied suppression and, upon the Commonwealth's motion, joined the four cases for trial.
Hobel was tried by a jury. In the robbery cases, the jury found him guilty of robbery, theft and receiving stolen property.1 In the other case, the jury found him guilty of terroristic threats, unlawful restraint, reckless endangerment (four counts) and fleeing or attempting to elude police.2 Because Hobel had a prior robbery conviction, the Commonwealth sought the mandatory minimum 10-year sentence for the robbery convictions. See 42 Pa.C.S. § 9714(a)(1). The trial court imposed consecutive sentences of 10 to 20 years for two of the robberies and concurrent sentences on all remaining charges. Hobel filed post-sentence motions raising, among other claims, sufficiency and weight of the evidence claims. When those motions were denied, he filed a timely appeal that was later dismissed for failure to file a brief. After Hobel's direct appeal rights were reinstated on collateral review, he filed these direct appeals, which we consolidated sua sponte .
Hobel first argues that the trial court erred in denying his suppression motion based on the alleged MPJA violations.3 The trial court gave a detailed summary of the evidence at the suppression hearing.
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