## Facts

- In the early morning of September 19, 1978, William Paul Walters died from a severe beating inflicted in the lobby of the Madden Hotel in Chambersburg and in an adjacent alley.
- Charles E. Sleighter and James Harmon were charged in connection with the beating and death.
- At a degree-of-guilt hearing following Sleighter’s guilty plea to murder generally, the court considered the autopsy report, excerpts from the guilty plea colloquy, preliminary hearing testimony of four witnesses, and Sleighter’s counseled statement.
- In the hotel lobby, Sleighter and Harmon confronted Walters after discussion of a gambling debt Walters allegedly owed Sleighter.
- Sleighter became upset, hit Walters, and demanded Walters surrender his rings; when Walters refused, Sleighter and Harmon kicked and hit him.
- Sleighter threw Walters to the floor and took Walters’s rings.
- During the assault, Harmon searched Walters’s pockets and removed change and a wallet containing about $25–$30; Harmon handed the wallet to Sleighter.
- Harmon also removed Walters’s watch, later gave it to Sleighter, and Sleighter attempted to hide it in a police cruiser.
- Walters went into the adjacent alley; Sleighter and Harmon followed and continued the beating until Walters lost consciousness.
- The unconscious Walters was dragged to a car behind the building and locked inside; he died from injuries caused by the beating.
- Sleighter pleaded guilty to murder generally in exchange for dismissal of other charges; the trial court found second-degree murder and imposed a life sentence.

## Issues

1. Whether the evidence was sufficient to establish an underlying robbery to support second-degree (felony) murder where the defendant asserted he took property under a claim of right to satisfy an alleged gambling debt.
2. Whether a broad claim-of-right theory can negate robbery for purposes of felony-murder when property is taken by force during a beating.

## Decision

- The Supreme Court of Pennsylvania affirmed the judgment of sentence.
- The Court held the evidence was sufficient to prove robbery and, therefore, second-degree (felony) murder.
- The Court rejected a broad claim-of-right theory as a basis to avoid robbery liability in these circumstances and overruled contrary reasoning expressed in a prior concurring opinion.
- Applying the sufficiency standard that evidence is viewed in the light most favorable to the Commonwealth, the Court concluded the taking of the rings, wallet, cash, and watch during the assault constituted robbery and the homicide occurred in the course of that felony.

## Legal Principles

- Second-degree murder (felony murder) is established when a homicide is committed during the perpetration of an enumerated felony, including robbery.
- Robbery is shown where property is taken from the person of another by force or violence as part of the criminal episode.
- For sufficiency review, the evidence is assessed in the light most favorable to the Commonwealth as verdict winner.
- A defendant’s asserted belief that he is owed money or property does not excuse a violent taking from the victim’s person; a claim of right does not negate robbery when force is used as self-help collection.

## Conclusion

The court upheld Sleighter’s life sentence for second-degree murder because the fatal beating occurred during a forcible taking of the victim’s property, constituting robbery, and an asserted claim of right to satisfy an alleged debt did not defeat robbery or felony-murder liability.


Commonwealth v. Sleighter, 495 Pa. 262, 433 A.2d 469 (Pa. 1981)