Michael Leigh Maleta appeals his conviction for carrying a firearm without a license, a first-degree misdemeanor, along with summary offenses of driving an unregistered vehicle and careless driving. The conviction stems from an incident on June 10, 2019, when Maleta crashed his vehicle into a telephone pole. Upon responding to the scene, Pennsylvania State Police Trooper Patrick Biddle discovered a loaded handgun in Maleta's car during an inventory search, finding that Maleta's firearms license had expired in 2010. Maleta claimed he was unaware of the expiration, stating he thought he had a valid license and had purchased the gun for $175. Evidence showed his license had been valid until 2010, and subsequent applications were denied. Maleta testified he had maintained his license for 23 years but lost it in 2017. The jury found him guilty of carrying a firearm without a license, and he was fined $500. On appeal, Maleta contests the sufficiency of the evidence regarding his eligibility for a firearms license, asserting that the Commonwealth did not prove he lacked a valid license at the time of the incident. The court applies a standard of reviewing evidence in the light most favorable to the verdict winner to determine the sufficiency of the evidence presented.
The court's analysis emphasizes that it cannot weigh evidence or replace the fact-finder's judgment. The Commonwealth's evidence does not need to eliminate all doubt about a defendant's innocence, but doubts can be resolved by the fact-finder unless the evidence is so weak that no reasonable conclusion can be drawn. The Commonwealth can meet its burden of proof for each crime element beyond a reasonable doubt with circumstantial evidence, and all evidence presented must be considered. The fact-finder has discretion regarding the credibility and weight of the evidence.
Maleta was convicted under Section 6106(a)(2) of the Crimes Code, which penalizes carrying a firearm without a valid license. The Commonwealth must prove the defendant's non-licensure beyond a reasonable doubt, and establish intent, knowledge, or recklessness regarding each element of the statute. Maleta contended that the evidence was insufficient to show he was ineligible for a license and that he believed he had a valid license at the time of the incident. However, both the trial court and the Commonwealth acknowledged the lack of evidence proving his ineligibility, leading to a conviction under the misdemeanor provision instead of the felony provision, which does not create an additional element for conviction.
Regarding Maleta's claim about having a valid license during the incident, his 2010-2015 license did not support his assertion, as it was expired by the time of the accident in June 2019. The jury was entitled to accept the evidence indicating that Maleta did not have a valid license on that date, further supported by a report showing his application's denial in 2015. Consequently, the court found sufficient evidence for the conviction and affirmed the judgment of sentence.
