Com. v. Edwards, D.
436 EDA 2015
| Pa. Super. Ct. | Jan 2, 2018Background
- Appellant Derrick Edwards appeals from a January 9, 2015 judgment of sentence in multiple Philadelphia County criminal cases.
- The Majority held that the Commonwealth’s peremptory strike of Juror 67 was racially motivated under Batson and vacated the judgment for a new trial.
- The dissenting judge contends the Batson analysis was misapplied and urges affirming the trial court’s ruling.
- The Strike Sheet on voir dire identified jurors by race and gender, but the judge who prepared it did so without Commonwealth involvement; its use is contested.
- The record allegedly failed to include a proper prima facie Batson record and the trial court did not explicitly determine a prima facie case.
- The dissent emphasizes deference to the trial court’s credibility findings regarding Juror 67’s demeanor and rejects substituting the appellate record for the trial court’s observations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie Batson showing required | Edwards did not prove a prima facie Batson case on the record | Commonwealth argues prima facie established and proper record exists | Edwards failed to prove prima facie case; not meritorious |
| Strike Sheet as evidence of discriminatory intent | Strike Sheet shows race/gender and suggests discrimination | Strike Sheet not evidence of Commonwealth’s discriminatory intent | Not persuasive; Strike Sheet alone not proof of discriminatory intent |
| Statistical evidence establishing discriminatory impact | Statistics show deliberate purge of African-Americans | Statistics are one factor among totality of circumstances | Statistics alone insufficient; deference to trial court's ultimate finding |
| Demeanor-based justification for Juror 67's strike | Trial court erred by crediting Commonwealth’s demeanor-based reason | Demeanor-based reasons are valid race-neutral explanations | Trial court’s credibility on demeanor should be respected; no clear error |
Key Cases Cited
- Commonwealth v. Harris, 817 A.2d 1033 (Pa. 2002) (three-part Batson test; deference to race-neutral explanations)
- Commonwealth v. Sanchez, 36 A.3d 24 (Pa. 2011) (addressing prima facie Batson and second/third prongs on direct appeal)
- Commonwealth v. Ligons, 971 A.2d 1125 (Pa. 2009) (totality of circumstances; statistics not dispositive alone)
- Commonwealth v. Roney, 79 A.3d 595 (Pa. 2013) (deference to trial court’s credibility; totality of circumstances)
- Commonwealth v. Williams, 980 A.2d 510 (Pa. 2009) (credibility determinations regarding demeanor warrant deference)
- Commonwealth v. Jackson, 562 A.2d 338 (Pa. Super. 1989) (demeanor as basis for peremptory challenge; appellate deferential review)
- Snyder v. Louisiana, 552 U.S. 472 (U.S. 2008) (demeanor-based explanations; limits on requiring judge’s personal recollection)
- Thaler v. Haynes, 559 U.S. 43 (U.S. 2010) (demeanor evidence and Batson where judge not required to recall demeanor)
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (original three-part Batson framework for evaluating peremptory challenges)
- Commonwealth v. Fletcher, 580 Pa. 403 (Pa. 2004) (full and complete record requirement for Batson review)