Commonwealth v. Timothy A. Watkins: Social Media Evidence and Conviction Affirmed (2023)

Commonwealth v. Watkins, 2024 Pa. Super. 77 (Pa. Super. Ct. 2024)

Background of the Case

In May 2022, employees of Asplundh Tree Service discovered that several trucks parked at a jobsite in Boggs Township, Centre County, Pennsylvania, had been broken into. Hundreds of pieces of specialized equipment, including climbing lanyards, carabiners, climbing saddles, and handsaws, were stolen. Approximately two weeks later, Asplundh employee Ethan Haines noticed postings on Facebook Marketplace listing tree service equipment for sale. Haines recognized the items as those stolen from Asplundh due to their distinctive color-coded tape and zip ties.

Lower Court Ruling

During the trial, the prosecution presented evidence including screenshots of the Facebook Marketplace listings, which were linked to an account named “Tim Watkins.” Trooper Lucas Dixon testified that Watkins admitted to creating the sales postings. The prosecution also introduced records from Facebook’s parent company, Meta, which linked the account to Watkins through his birthdate, hometown, and profile picture. The jury convicted Watkins of Receiving Stolen Property and Driving on a Suspended License. Watkins argued that the trial court abused its discretion in admitting the social media evidence and that his conviction was not supported by the weight of the evidence.

Superior Court Ruling

The Pennsylvania Superior Court reviewed the trial court’s denial of Watkins’ motion in limine, which sought to exclude the Facebook screenshots. Under Pennsylvania Rule of Evidence 901, the proponent of evidence must introduce sufficient evidence that the matter is what it purports to be. The court found that the prosecution met this burden by presenting testimony from Trooper Dixon, Haines, and Meta’s records, which collectively authenticated the Facebook listings as being posted by Watkins.

Reasoning

The Superior Court concluded that the trial court did not abuse its discretion in admitting the Facebook screenshots. The court noted that Pennsylvania Rule of Evidence 901(b)(11) specifically addresses the authentication of digital evidence, including social media postings. The prosecution provided ample evidence to authenticate the Facebook Marketplace listings as posts created by Watkins. The court found that Watkins’ own admissions, combined with corroborating evidence from Meta and Asplundh employees, supported the trial court’s decision to admit the screenshots.

Regarding Watkins’ challenge to the weight of the evidence, the Superior Court reiterated that the jury was free to believe the testimony of the Asplundh employees, who identified the equipment based on its distinctive markings, and to reject Watkins’ alternative explanations. The court found that the evidence presented by the Commonwealth was sufficient to support Watkins’ conviction beyond a reasonable doubt.

The Pennsylvania Superior Court affirmed the trial court’s ruling, concluding that the admission of the social media evidence was appropriate and that the weight of the evidence supported Watkins’ conviction. The judgment of sentence was upheld.