Com. v. Baynes, P.
Com. v. Baynes, P. No. 1908 WDA 2016
| Pa. Super. Ct. | Aug 14, 2017Background
- Peter Baynes was convicted after a jury trial for multiple offenses stemming from a multi-day, severe assault on his girlfriend, Anna Gomez; he received an aggregate sentence of 13–26 years.
- Gomez testified to repeated beatings over a three-day span with serious injuries; police and medical evidence corroborated significant trauma.
- Baynes testified he was away for about two hours during which he claims unknown assailants attacked Gomez; he maintained he did not commit the assaults.
- On collateral review, Baynes filed a timely PCRA petition claiming trial counsel was ineffective for failing to investigate or call a defense witness, Robert Spencer.
- Baynes asserted Spencer would rebut Gomez’s testimony that Spencer threatened her during the second day of the attack and would support Baynes’s defense that others attacked Gomez.
- The PCRA court denied relief without an evidentiary hearing; the Superior Court affirmed, finding procedural and substantive defects in Baynes’s ineffectiveness claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel was ineffective for failing to investigate or call Robert Spencer | Baynes: counsel knew Spencer, subpoenaed him, and he was present; Spencer would have testified he was not at the apartment or threatening Gomez, undermining her testimony and supporting Baynes’s alternate-perpetrator defense | Commonwealth/PCRA court: Baynes failed to provide a signed witness certification, so Spencer’s testimony was inadmissible; any rebuttal on a minor point would not have altered the verdict | Denied — PCRA court properly dismissed without a hearing; Baynes failed to satisfy statutory witness-certification requirements and did not show prejudice |
Key Cases Cited
- Commonwealth v. Conway, 14 A.3d 101 (Pa. Super. 2011) (standard of review for PCRA denials)
- Commonwealth v. Boyd, 923 A.2d 513 (Pa. Super. 2007) (deference to PCRA court findings when supported by record)
- Commonwealth v. Ford, 44 A.3d 1190 (Pa. Super. 2012) (no deference to legal conclusions)
- Commonwealth v. Miller, 102 A.3d 988 (Pa. Super. 2014) (dismissal without evidentiary hearing reviewed for abuse of discretion)
- Commonwealth v. Perry, 959 A.2d 932 (Pa. Super. 2008) (three-prong ineffective assistance standard)
- Commonwealth v. Walls, 993 A.2d 289 (Pa. Super. 2010) (elements for ineffectiveness claim based on failure to call a witness)