Com. v. Crawford, H.
2284 MDA 2015
| Pa. Super. Ct. | Dec 14, 2016Background
- On April 21, 2014, Holly Ann Crawford and her boyfriend James Roche traveled to Ronald “Barney” Evans’s home; both Evans (73) and his son Jeffrey were found shot to death that night. Crawford and Roche were later arrested; Roche confessed and Crawford gave multiple statements after Miranda warnings. Jury convicted Crawford of two counts each of first‑degree murder and criminal conspiracy; trial court sentenced her to life imprisonment.
- Key inculpatory evidence: recorded and oral statements by Crawford (after arrest), admissions/confessions to family members (including her daughters and a jailmate), Roche’s statement and confession, physical evidence linking a broken trigger guard from Crawford’s household .22 rifle to the victims’ porch, knives and a .44 revolver recovered from the woods, flight into woods after police arrival, and post‑crime behavior (attempt to flee to Philadelphia, letters, attempts to conceal evidence).
- Crawford moved to suppress her statements (claimed intoxication/withdrawal); the trial court held a suppression hearing, found she knowingly and voluntarily waived Miranda, and denied suppression. On appeal she challenged denial of suppression, admissibility of pre‑death victim photos, sufficiency of evidence, and the trial court’s refusals to give jury instructions (involuntary manslaughter, mistake/ignorance, duress, voluntary intoxication).
- The Superior Court reviewed the record, credited the trial court’s factual findings (including police testimony), agreed the victim photos were erroneously admitted but found the error harmless given overwhelming other evidence, and affirmed the convictions and sentence largely on the trial court’s comprehensive opinion.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Crawford) | Held |
|---|---|---|---|
| Denial of motion to suppress statements | Statements were voluntary and lawfully obtained after Miranda waiver | Statements involuntary due to intoxication/withdrawal and illness; waiver not knowing/voluntary | Suppression denial affirmed: Miranda warnings given, totality of circumstances show voluntary waiver and capacity to waive |
| Admission of pre‑death photos of victims | Photos relevant as life‑in‑being/context; limited display with cautionary instruction | Photos irrelevant, prejudicial, inflammatory; should be excluded | Admission was error but harmless beyond a reasonable doubt given overwhelming admissible evidence of guilt |
| Sufficiency of evidence for 1st‑degree murder and conspiracy | Evidence (statements, confessions, physical evidence, flight, conduct) establishes intent, agreement, and overt acts | Crawford claimed she was only a decoy/there for pills; denied responsibility | Convictions upheld: evidence (including circumstantial) sufficient to prove specific intent, conspiracy, and accomplice liability |
| Refusal to instruct on involuntary manslaughter, mistake of fact, duress, voluntary intoxication | If supported by evidence, instruction should be given | Requested instructions were warranted by evidence of intoxication, Roche’s threats/abuse, and alleged mistaken belief Roche wouldn’t act | Refusals affirmed: record lacked evidence to support those instructions (Crawford consistently denied culpability; no evidence she acted under duress or was too impaired to form intent) |
Key Cases Cited
- Commonwealth v. Jones, 988 A.2d 649 (Pa. 2010) (standard of review for suppression rulings)
- Commonwealth v. Rivers, 644 A.2d 710 (Pa. 1994) (pre‑death photographs are irrelevant to guilt/innocence)
- Commonwealth v. Jordan, 65 A.3d 318 (Pa. 2013) (life‑in‑being testimony may be admissible under limited circumstances)
- Commonwealth v. Melvin, 103 A.3d 1 (Pa. Super. 2014) (harmless error doctrine and sufficiency review principles)
- Commonwealth v. Hitcho, 123 A.3d 731 (Pa. 2015) (elements of first‑degree murder: intentional, premeditated killing)
- Commonwealth v. McCall, 911 A.2d 992 (Pa. Super. 2006) (elements of criminal conspiracy)
- Commonwealth v. Demarco, 809 A.2d 256 (Pa. 2002) (when duress instruction required under Section 309)
- Commonwealth v. Hutchinson, 25 A.3d 277 (Pa. 2011) (voluntary intoxication/diminished capacity limited to defendants who admit culpability)
- Commonwealth v. Ventura, 975 A.2d 1128 (Pa. Super. 2009) (confession voluntariness and effect of intoxication)