Com. v. Fields, R., 302 EDA 2024

Reggie J. Fields was convicted by a jury in Philadelphia County of several crimes including involuntary deviate sexual intercourse, conspiracy, promoting prostitution of a minor, trafficking in minors, involuntary servitude, sexual exploitation of children, and unlawful contact with a minor.
The case arose from events in April 2017 involving a 14-year-old victim who was subjected to sexual abuse and trafficking after leaving home.
During trial, a police officer, Officer Capaldi, improperly characterized Fields's statement as a “confession.”
Defense counsel objected and requested either a mistrial or, preferably, a curative instruction to the jury clarifying no confession existed in Fields's statement.
The trial court denied the motion for mistrial, instead giving a strong curative instruction and permitting follow-up questioning to clarify there was no confession.
On appeal, Fields challenged only the denial of his mistrial motion, arguing the officer’s “confession” comment irreparably prejudiced the jury.

Issue	Fields's Argument	Commonwealth's Argument	Held
Was it error for the trial court to deny a mistrial after an officer repeatedly called a statement a "confession," when in fact Fields had not confessed?	The officer’s statement prejudiced the jury and a curative instruction could not “un-ring the bell.”	Proper curative instructions were sufficient; no incurable prejudice.	Denial of mistrial was proper; the cautionary instruction sufficed.

Commonwealth v. Bryant, 67 A.3d 716 (Pa. 2013) (defining when a mistrial is appropriate for prejudicial incidents at trial)
Commonwealth v. Cash, 137 A.3d 1262 (Pa. 2016) (stating the presumption that juries follow curative instructions)
Commonwealth v. Walker, 954 A.2d 1249 (Pa. Super. 2008) (emphasizing trial court’s discretion and vantage in assessing jury prejudice)