In the case of Commonwealth of Pennsylvania v. Markese Denashawn Lampley, (AKA Mileage Galor Bey) the Superior Court of Pennsylvania upheld the judgment rendered by the lower court. Lampley was sentenced to life imprisonment without the possibility of parole, along with an additional term of 13 to 44 years, following his conviction on multiple charges related to a series of events on January 25, 2020. These charges included second-degree murder, aggravated assault, robbery, and numerous motor vehicle violations.
Lampley was initially charged on April 15, 2020. His appointed counsel filed several pre-trial motions, including requests for a change of venue and dismissal of charges, all of which were denied. In November 2020, Lampley retained a private attorney, Jason E. Nard, who later filed a motion in limine to exclude certain evidence, such as photographs of the deceased victim and a letter written by Lampley. This motion was partially addressed by the trial court, which allowed the letter as evidence.
As the trial date approached, Lampley decided to proceed without legal representation, prompting the trial court to conduct a Grazier hearing to ensure that his waiver of counsel was knowing, voluntary, and intelligent. The court found that Lampley’s decision met these criteria and appointed Attorney Nard as standby counsel. The trial commenced on June 24, 2021, with jury selection. After a four-day trial, Lampley was found guilty of multiple offenses, including second-degree murder, aggravated assault, robbery, and various motor vehicle violations.
The sentencing phase took place on August 18, 2021. After considering the pre-sentence investigation report, the gravity of the offenses, and the impact on the community and victims, the court imposed a sentence of life imprisonment without parole, followed by 13 to 44 years for the other charges. Lampley subsequently filed post-sentence motions, asserting that the court lacked jurisdiction over him based on him being a sovereign citizen. These motions were denied as frivolous.
Lampley proclaimed himself a sovereign citizen shortly before the trial, insisting that the court lacked jurisdiction over him and requested to be addressed as “Mileage Galor Bey.”
Lampley raised three main issues on appeal:
1) Whether his waiver of counsel was knowing, voluntary, and intelligent.
2) Whether his right to self-representation was violated by the participation of standby counsel.
3) Whether the evidence was sufficient to support convictions for aggravated assault.
Regarding Lampley’s right to self-representation, the Superior Court scrutinized the role of standby counsel during the trial. It was established that Lampley had agreed to Attorney Nard’s participation at various stages, including sidebar discussions and in-chamber hearings. Lampley did not object to Nard’s involvement at any point, indicating his acquiescence.
Lastly, the court addressed the sufficiency of the evidence supporting the aggravated assault convictions. It found that the evidence presented at trial was adequate to sustain the guilty verdicts. Consequently, the Superior Court affirmed the trial court’s decision, concluding that Lampley’s constitutional rights were upheld throughout the trial process and that the evidence was sufficient to support his convictions.