The opinion
J-A26041-25
NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37
COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF
: PENNSYLVANIA
:
v. :
:
:
STEPHANIE ANNETTE BROWN :
:
Appellant : No. 281 WDA 2024
Appeal from the Judgment of Sentence Entered February 13, 2024
In the Court of Common Pleas of Allegheny County Criminal Division at
No(s): CP-02-CR-0007084-2023
BEFORE: OLSON, J., STABILE, J., and KING, J.
JUDGMENT ORDER BY KING, J.: FILED: October 15, 2025
Appellant, Stephanie Annette Brown, appeals pro se from the judgment
of sentence entered in the Allegheny County Court of Common Pleas, following
her bench trial conviction for simple assault and disorderly conduct. We
dismiss the appeal.
The relevant facts and procedural history of this matter are as follows.
On May 20, 2023, Appellant used a baseball bat to assault a victim in a
Walmart bathroom. As a result of the assault, the victim suffered a bodily
injury. On February 13, 2024, following a bench trial, the court convicted
Appellant of the aforementioned offenses. That same day, the court
sentenced Appellant to 18 months’ probation for simple assault, with no
further penalty for the disorderly conduct. On February 22, 2024, trial counsel
filed a motion seeking to withdraw representation, which the court granted on
March 5, 2024. On March 8, 2024, Appellant timely filed a pro se notice of
J-A26041-25
appeal.
On May 6, 2024, this Court remanded to the trial court for a Grazier1
hearing. After conducting the hearing, the trial court determined that
Appellant wished to proceed pro se. On September 5, 2024, the court ordered
Appellant to file a Pa.R.A.P. 1925(b) statement of errors complained of on
appeal within 21 days of the entry of the order. On December 11, 2024,
Appellant filed an untimely Rule 1925(b) statement, arguing that she was a
foreign diplomatic agent immune from prosecution under the Diplomatic
Relations Act of 1978 and the Vienna Convention on diplomatic relations and
raising jurisdictional issues related to this claim.2
Preliminarily, it is well settled that only issues properly raised in a timely
Rule 1925(b) statement are preserved for appellate review. See
Commonwealth v. Castillo, 585 Pa. 395, 888 A.2d 775 (2005); Pa.R.A.P.
1925(b)(4)(vii) (stating that “[i]ssues not included in the Statement and/or
not raised in accordance with the provisions of this paragraph (b)(4) are
waived”). “If there has been an untimely filing, this Court may decide the
appeal on the merits if the trial court had adequate opportunity to prepare an
opinion addressing the issues being raised on appeal.” Commonwealth v.
____________________________________________
1 Commonwealth v. Grazier, 552 Pa. 9, 713 A.2d 81 (1998).
2 Specifically, Appellant claimed that she was an agent of “the Sultanate Ea Al
Maurikanuus Estados,” a country which does not exist, but which is sometimes
invoked in various name forms by adherents of the Moorish or sovereign
citizenship political movements. See, e.g., El Ameen Bey v. Stumpf, 825
F.Supp. 2d 537 (D.N.J. 2011).
-2-
J-A26041-25
Burton, 973 A.2d 428, 433 (Pa.Super. 2009). See also Commonwealth v.
Baker, 311 A.3d 12, 18 (Pa.Super. 2024).
Instantly, Appellant raises a litany of issues on appeal, none of which
were preserved in her Rule 1925(b) statement. As Appellant did not preserve
her appellate claims in a Rule 1925(b) statement, the trial court did not
address them on the merits. Consequently, Appellant’s claims are waived on
this ground.3 See Castillo, supra. See also Baker, supra; Burton, supra.
Further:
[A]ppellate briefs and reproduced records must materially
conform to the requirements of the Pennsylvania Rules of
Appellate Procedure. This Court may quash or dismiss an
appeal if the appellant fails to conform to the requirements
set forth in the Pennsylvania Rules of Appellate Procedure.
Although this Court is willing to liberally construe materials
filed by a pro se litigant, pro se status confers no special
benefit upon the appellant. To the contrary, any person
choosing to represent [herself] in a legal proceeding must,
to a reasonable extent, assume that [her] lack of expertise
and legal training will be [her] undoing.
Commonwealth v. Adams, 882 A.2d 496, 497-98 (Pa.Super. 2005)
(internal citations omitted). See also Pa.R.A.P. 2101 (explaining that briefs
which fail to conform with requirements of rules may be suppressed, and, if
____________________________________________
3 In its opinion, the trial court stated that Appellant had waived the issues
raised in her Rule 1925(b) statement for failure to preserve them in the trial
court. (See Trial Court Opinion, 12/23/24, at 3). We agree with the trial
court that the issues raised in Appellant’s Rule 1925(b) statement would be
waived for failure to preserve them in the trial court. See Pa.R.A.P. 302(a)
(stating appellant cannot raise new issues for first time on appeal).
Nevertheless, Appellant has seemed to abandon the issues raised in her Rule
1925(b) statement in favor of new theories of relief on appeal.
-3-
J-A26041-25
defects in brief are substantial, appeal may be quashed or dismissed).
Here, Appellant’s brief fails to adhere to the Rules of Appellate
Procedure. Appellant’s brief consists of 35 pages of bald allegations of due
process violations and judicial and prosecutorial misconduct, none of which
are supported by citation to the record or any relevant legal authority. See
Pa.R.A.P. 2119(a) (stating argument shall be divided into as many sections as
there are questions presented, followed by discussion with citation to relevant
legal authority). Appellant’s failure to comply with the Rules of Appellate
Procedure concerning Rule 1925(b) issue preservation and our briefing
requirements impedes our meaningful review of this case, requiring dismissal
of the appeal. See Pa.R.A.P. 2101. Accordingly, we dismiss the appeal.
Appeal dismissed.
DATE: 10/15/2025
-4-