Com. v. Eden, J.
Com. v. Eden, J. No. 1401 EDA 2015
| Pa. Super. Ct. | May 23, 2017Background
- Victims A.S. (male, 12–13 at first incident) and M.O. (female, ~11–12 at incidents) alleged multiple sexual assaults by defendant Jeffrey A. Eden, their brother‑in‑law and family figure, occurring between the mid‑1990s and 2011 in Philadelphia.
- A.S. reported three incidents (including oral sex and digital/genital contact) following disclosures to school and prosecutors in 2011; M.O. reported recurring conduct (fondling during "movie nights," underwear removal, sexual comments, and offers of money for intercourse).
- Eden was charged and tried on consolidated indictments; a jury convicted him of multiple offenses including corrupting a minor, unlawful contact with a minor, rape by forcible compulsion, involuntary deviate sexual intercourse (IDSI), statutory sexual assault, sexual assault, and indecent assault.
- Post‑trial, Eden received an aggregate sentence of 15–30 years’ incarceration; he appealed raising numerous claims (procedural/charging defects, evidentiary rulings, sufficiency/weight of evidence, jury‑instruction errors, and sentencing challenges).
- The Superior Court affirmed convictions and most sentencing rulings but held the mandatory minimum sentence imposed under 42 Pa.C.S. § 9718 for IDSI unconstitutional under Alleyne and Wolfe, vacating the IDSI sentence while leaving concurrent sentences intact.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Eden) | Held |
|---|---|---|---|
| Failure to file bill of information under Pa.R.Crim.P. 560(a) | Rule 560 was satisfied procedurally; no dismissal warranted | Commonwealth failed to file informations; dismissal required | Waived (no omnibus pretrial motion); claim denied |
| Admission of ADA Shields’s testimony about A.S.’s prior statements | Testimony admissible (prior consistent statements/for context) | Testimony was hearsay, irrelevant, improper in Commonwealth’s case‑in‑chief | Waived (no timely specific objection); claim denied |
| Sufficiency/weight of evidence for sexual‑offense convictions | Evidence (victim testimony, circumstances, pattern) supports convictions beyond reasonable doubt; weight appropriate | Testimony was inconsistent, uncorroborated, and insufficient; verdict against weight | Convictions supported: sufficiency and weight claims rejected |
| Mandatory minimum under 42 Pa.C.S. § 9718 for IDSI (Alleyne challenge) | § 9718 proper to apply at sentencing; no jury finding required beyond conviction | Mandatory minimum requires judge fact‑finding in violation of Alleyne; sentence illegal | Court agrees with defendant; § 9718 application unconstitutional here — IDSI sentence vacated (concurrent sentences left intact) |
Key Cases Cited
- Alleyne v. United States, 133 S. Ct. 2151 (2013) (facts increasing mandatory minimum must be found by a jury beyond a reasonable doubt)
- Commonwealth v. Wolfe, 106 A.3d 800 (Pa. Super. 2014) (Pa. Super. holding § 9718 facially unconstitutional under Alleyne)
- Commonwealth v. Rhodes, 510 A.2d 1217 (Pa. 1986) (forcible compulsion includes psychological and positional coercion of a child by an adult)
- Commonwealth v. Tarrach, 42 A.3d 342 (Pa. Super. 2012) (standard of review for sufficiency: view evidence in light most favorable to verdict winner)
- Commonwealth v. Walls, 926 A.2d 957 (Pa. 2007) (sentencing court may depart from guidelines if it provides individualized, reasonable reasons)