Comm. v. Davison, 2018 PA Super 7 (Jan. 18, 2018)

This was an appeal out of Allegheny County. Shawn Davison had been convicted of robbery and harassment.  On appeal he complained that he was convicted of robbery without sufficient evidence.  Specifically, he complains that the victim of the robbery “never stated at trial that she had been in substantial pain, which is a necessary element to prove she sustained bodily injury.”

The Superior Court held that “caselaw does not require a victim to quantify the precise level of the pain she sustained to establish that she sustained bodily injury in the course of a robbery.”  Thus, the conviction was upheld.