Pennsylvania v. Chambers (majority)Annotate this Case
In this appeal, the issue before the Pennsylvania Supreme Court centered on whether the trial evidence sufficed to support a conspiracy conviction, as well as derivative convictions for aggravated assault with a deadly weapon and possessing instruments of crime. The case started after a street fight into which additional persons entered. Richard Chambers' vehicle was blocking egress for Calvin Wilson. Wilson drove up on the curb and squeezed his vehicle past Chambers' Jeep without making contact with it. However, as he passed Chambers, “words were exchanged.” Wilson parked his car and approached Chambers, continuing to press Chambers as to why he and the Jeep were impeding access to the driveway. The two men walked toward each other as their verbal spat escalated. As Wilson got closer to the Jeep, he noticed at least two women inside. Finally, Wilson and Chambers met, and “fists were flying.” According to Wilson, Chambers threw the first punch and Wilson retaliated in kind to defend himself. Philadelphia police arrived to a "pile of people." Wilson was not charged, but Chambers was with aggravated assault, criminal conspiracy, possessing instruments of crime, simple assault and reckless endangerment. The Supreme Court held that, under the particular circumstances of this case, the Commonwealth did not meet its evidentiary burden of proof beyond a reasonable doubt that Chambers was guilty of criminal conspiracy. Without a conspiracy, the evidence was similarly insufficient to prove Chambers guilty of conspiratorial liability, aggravated assault, and of possessing instruments of crime. Chambers' sentence was vacated, and the case remanded for resentencing on the remaining unchallenged convictions for terroristic threats, simple assault and reckless endangerment.