Com. v. Eakin, S.
242 A.3d 387
Pa. Super. Ct.2020Background
- Police observed Steven Eakin driving the wrong way for ~0.5 mile; he was stopped, exhibited DUI indicators, arrested, and his blood was drawn at a hospital around 10:00 PM.
- Eakin was charged with DUI (general impairment and highest rate of alcohol, second offense).
- Preliminary hearing was continued, then held in absentia when Eakin failed to appear; he later appeared and proceeded pro se at various hearings.
- Eakin filed an omnibus pre-trial motion (suppress statements, quash information, suppress blood test), and the trial court held hearings on Feb. 27 and May 17, 2018; the court denied relief on Sept. 28, 2018.
- The record lacked an on-the-record colloquy showing Eakin knowingly and intelligently waived counsel before the suppression hearing as required by Pa.R.Crim.P. 121(C).
- Eakin later signed a written waiver before trial, was tried pro se, convicted, and sentenced; the Superior Court vacated the judgment and remanded because the earlier suppression-hearing waiver was not validated on the record.
Issues
| Issue | Commonwealth's Argument | Eakin's Argument | Held |
|---|---|---|---|
| Whether the information should be quashed for lack of lawful police jurisdiction | Jurisdiction was lawful; evidence and procurement of charges valid | Stop and ensuing actions occurred outside lawful jurisdiction; information should be quashed | Court did not reach merits: judgment vacated and case remanded because suppression-hearing waiver was not on the record per Pa.R.Crim.P. 121(C) |
| Whether statements and blood results should be suppressed for failure to give Miranda and O’Connell warnings | Warnings were not required or were adequate; evidence admissible | Officers failed to give Miranda at stop and O’Connell warnings at blood draw; suppress statements and blood results | Court did not decide merits: suppression hearing invalidated by lack of on-the-record waiver; remand for further proceedings (new suppression hearing/trial) |
Key Cases Cited
- Commonwealth v. Johnson, 158 A.3d 117 (Pa. Super. 2017) (requires on-the-record colloquy under Pa.R.Crim.P. 121(C) before a defendant may waive counsel at critical stages, including suppression hearings)
- Commonwealth v. Murphy, 214 A.3d 675 (Pa. Super. 2019) (appellate court may review waiver-of-counsel issues sua sponte)
- Commonwealth v. McAleer, 748 A.2d 670 (Pa. 2000) (right to counsel applies at all critical stages)
- Commonwealth v. Fill, 202 A.3d 133 (Pa. Super. 2019) (summarizing that suppression hearings are critical stages requiring counsel protections)
- Commonwealth v. Phillips, 141 A.3d 512 (Pa. Super. 2016) (discusses continuity and effect of valid waiver of counsel)
- Commonwealth v. O’Connell, 555 A.2d 873 (Pa. 1989) (discusses warnings and procedures related to chemical testing)
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishes custodial interrogation warning requirements)