deadly weapon presumption (Pennsylvania) · Go Syfert
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deadly weapon presumption in Pennsylvania

8 Pennsylvania opinions name it 2 courts 1987–2026 7 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Commonwealth v. O'SEAROgreen
pa · 1976 · cited in 5 Pennsylvania opinions naming this issue, 2024–2025
2 sentences

2025Commonwealth v. Ballard, 80 A.3d 380, 390 (Pa. 2013) (emphasis added; citation modified); see also Commonwealth v. Packer, 168 A.3d 161, 168 (Pa. 2017) (“Malice is a legal term” that encompasses “not only a particular -7- J-S40042-25 ill-will, but every case where there is a wickedness of disposition, hardness of heart, cruelty, recklessness of consequences, and a mind regardless of social duty, although a particular person may not be intended to be injured.” (citation omitted)); Newton, 318 A.3d at 139 (“The deadly weapon presumption is a presumption of fact founded on human experience, since

2024The deadly weapon presumption is a presumption of fact founded on human experience, since “one does not normally use a deadly weapon on a vital part of another’s body unless he intends to kill.” Commonwealth v. O’Searo, 352 A.2d 30, 37 (Pa. 1976).

55
Macklin v. Court of Common Pleas of Philadelphia Countygreen
pa · 2013 · cited in 2 Pennsylvania opinions naming this issue, 2024–2025
2 sentences

2025Commonwealth v. Ballard, 80 A.3d 380, 390 (Pa. 2013) (emphasis added; citation modified); see also Commonwealth v. Packer, 168 A.3d 161, 168 (Pa. 2017) (“Malice is a legal term” that encompasses “not only a particular -7- J-S40042-25 ill-will, but every case where there is a wickedness of disposition, hardness of heart, cruelty, recklessness of consequences, and a mind regardless of social duty, although a particular person may not be intended to be injured.” (citation omitted)); Newton, 318 A.3d at 139 (“The deadly weapon presumption is a presumption of fact founded on human experience, since

2024Commonwealth v. Ballard, 80 A.3d 380, 390 (Pa. 2013) (emphasis added); see also Commonwealth v. O’Searo, 352 A.2d 30, 37 (Pa. 1976) (stating the deadly weapon presumption is a presumption of fact “founded on human experience,” since “[o]ne does not normally use a deadly weapon on a vital part of another’s body unless he intends to kill.” (citation omitted)). - 14 - J-S41009-24 Our Supreme Court has held the period of reflection required … to establish the specific intent to kill may be very brief[.

22
Commonwealth v. Kluskagreen
pa · 1938 · cited in 2 Pennsylvania opinions naming this issue, 2024–2024
2 sentences

2024Commonwealth v. Kluska, 3 A.2d 398, 402 (Pa. 1939).

2024Commonwealth v. Kluska, 3 A.2d 398, 402 (Pa. 1939).

22
Com. v. Newton, I.green
pasuperct · 2024 · cited in 3 Pennsylvania opinions naming this issue, 2025–2026
2 sentences

2025“The deadly weapon presumption is -7- J-S47032-24 a presumption of fact founded on human experience, [as] one does not normally use a deadly weapon on a vital part of another’s body unless he intends to kill.” Id. (quotation marks and citation omitted).

2025Commonwealth v. Ballard, 80 A.3d 380, 390 (Pa. 2013) (emphasis added; citation modified); see also Commonwealth v. Packer, 168 A.3d 161, 168 (Pa. 2017) (“Malice is a legal term” that encompasses “not only a particular -7- J-S40042-25 ill-will, but every case where there is a wickedness of disposition, hardness of heart, cruelty, recklessness of consequences, and a mind regardless of social duty, although a particular person may not be intended to be injured.” (citation omitted)); Newton, 318 A.3d at 139 (“The deadly weapon presumption is a presumption of fact founded on human experience, since

13
Commonwealth v. Packergreen
pa · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025Commonwealth v. Ballard, 80 A.3d 380, 390 (Pa. 2013) (emphasis added; citation modified); see also Commonwealth v. Packer, 168 A.3d 161, 168 (Pa. 2017) (“Malice is a legal term” that encompasses “not only a particular -7- J-S40042-25 ill-will, but every case where there is a wickedness of disposition, hardness of heart, cruelty, recklessness of consequences, and a mind regardless of social duty, although a particular person may not be intended to be injured.” (citation omitted)); Newton, 318 A.3d at 139 (“The deadly weapon presumption is a presumption of fact founded on human experience, since

11
Commonwealth v. Talbertgreen
pasuperct · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025Commonwealth v. Ballard, 80 A.3d 380, 390 (Pa. 2013) (emphasis added; citation modified); see also Commonwealth v. Packer, 168 A.3d 161, 168 (Pa. 2017) (“Malice is a legal term” that encompasses “not only a particular -7- J-S40042-25 ill-will, but every case where there is a wickedness of disposition, hardness of heart, cruelty, recklessness of consequences, and a mind regardless of social duty, although a particular person may not be intended to be injured.” (citation omitted)); Newton, 318 A.3d at 139 (“The deadly weapon presumption is a presumption of fact founded on human experience, since

11
Com. v. Fitzpatrick, J., IIIgreen
pasuperct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025Regarding the specific intent to kill, we have observed that “murder may be committed without a motive, either actual or apparent, but an established motive may go to prove the related intent[,] just as an absence of motive may be used to deny the existence of intent.” Commonwealth v. Fitzpatrick, 159 A.3d 562, 567 (Pa. Super. 2017) (emphasis in original; citation omitted).

11
Commonwealth v. Hicks, C., Aplt.green
pa · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024Commonwealth v. Hicks, 156 A.3d 1114, 1124 (Pa. 2017); see also Commonwealth v. O’Searo, 352 A.2d 30, 37 (Pa. 1976) (stating the deadly weapon presumption is a presumption of fact “founded on human experience,” since “[o]ne does not normally use a deadly weapon on a vital part of another’s body unless he intends to kill.” (citation omitted)). [T]he period of reflection required … to establish the specific intent to kill may be very brief[.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (1)

CaseCitedYears
Rivenbark v. COM. PA. BD. OF PROB. & P. green
pa · 1985
2 sentences

1987Petitioner contends that the Board erred as a matter of law in determining that the sock was a weapon, or, in the alternative, that, even if the sock was a weapon, the Board had no authority to recommit him as a technical parole violator for possession of the weapon in light of our Supreme Courts decision in Rivenbark v. Pennsylvania Board of Probation and Parole, 509 Pa. 248 , 501 A.2d 1110 (1985).

1987Petitioner contends that the Board erred as a matter of law in determining that the sock was a weapon, or, in the alternative, that, even if the sock was a weapon, the Board had no authority to recommit him as a technical parole violator for possession of the weapon in light of our Supreme Courts decision in Rivenbark v. Pennsylvania Board of Probation and Parole, 509 Pa. 248 , 501 A.2d 1110 (1985).

11987–1987

Where else courts name it

CA 54 (1963–2026) TX 48 (1985–2026) WA 11 (1984–2019) PA 8 (1987–2026) GA 7 (1978–2019) FL 6 (1902–2009) CO 6 (1977–2025) OH 5 (2000–2024) NC 5 (1931–2020) WY 4 (1977–2015) MS 4 (1896–2019) NM 4 (1997–2021) KS 4 (1997–2015) MD 3 (1952–1986) CT 3 (1988–2022) MO 3 (1975–2016) NV 3 (2016–2017) VA 3 (2000–2015) IL 2 (1984–1993) IA 2 (1896–1925) OK 2 (1926–2016) KY 2 (1960–2010)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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