Com. v. Goodman, J.
1833 WDA 2016
| Pa. Super. Ct. | Sep 13, 2017Background
- Defendant Jeffrey A. Goodman was tried by jury in Venango County for the shooting death of his wife, Cathy Goodman; convicted of first-degree murder and aggravated assault; sentenced to life imprisonment and ordered to pay restitution.
- Police responded after a 911 call reporting the husband had killed his wife and was still inside with a rifle; defendant exited the house and told officers, "I done it. I’ve had enough. I’m done. She’s dead."
- Officers observed gunpowder odor, blood spatter, bone fragments, and the victim on a couch with a rifle partially on her body; a bullet passed through the couch consistent with a front-to-back trajectory.
- Forensic pathologist testified the victim died from a high-power rifle gunshot to the head causing massive cranial destruction; powder stippling on the victim’s hand indicated intermediate-range firing and suggested she raised her hand to shield herself.
- Defendant admitted on videotape and at trial that he retrieved a rifle, loaded it during an argument, pointed it at the victim, fired, reloaded, and made statements indicating intent to ensure the victim was killed; defense argued lack of direct ballistic/fingerprint testing and claimed heat-of-passion or accidental shooting.
- Post-sentence motions were denied; this appeal challenges evidentiary sufficiency and the discretionary aspect of sentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for 1st-degree murder | Commonwealth: circumstantial evidence (admissions, weapon on vital area, forensic pathologist) supports intentional killing | Goodman: no direct proof he fired the fatal shot or that rifle matched bullet; argued lack of intent/heat of passion or accidental discharge | Affirmed: evidence (admissions + deadly weapon to vital area + stippling/trajectory) sufficient to infer intent and support 1st-degree murder conviction |
| Sufficiency of evidence for aggravated assault | Commonwealth: causing serious bodily injury by shooting supports aggravated assault conviction | Goodman: no proof he intended serious bodily injury or fired the gun | Affirmed: killing by gunshot to head established serious bodily injury and intent may be inferred from circumstances |
| Discretionary aspect of sentencing | Commonwealth: life sentence mandated for 1st-degree murder | Goodman: urged mitigation, shorter term and parole eligibility | Affirmed: statute mandates death or life for 1st-degree murder; life sentence legal and not appealable as abuse of discretion |
Key Cases Cited
- Commonwealth v. Widmer, 744 A.2d 745 (Pa. 2000) (standard for appellate sufficiency review)
- Commonwealth v. Ratsamy, 934 A.2d 1233 (Pa. 2007) (appellate review of sufficiency—view evidence in light most favorable to Commonwealth)
- Commonwealth v. Ramtahal, 33 A.3d 602 (Pa. 2011) (first-degree murder may be proven circumstantially; use of deadly weapon on vital part supports specific intent)
- Commonwealth v. Baez, 759 A.2d 936 (Pa. Super. 2000) (intent to kill can form in seconds)
- Commonwealth v. Fortune, 68 A.3d 980 (Pa. Super. 2013) (aggravated assault sustained where defendant pointed gun at victim’s forehead and threatened, showing intent and substantial step toward causing serious injury)
- Commonwealth v. Martuscelli, 54 A.3d 940 (Pa. Super. 2012) (intent to cause serious bodily injury may be proven circumstantially)
- Commonwealth v. Walker, 656 A.2d 90 (Pa. 1994) (provocation known prior to the fatal act may undercut heat-of-passion defense)
- Commonwealth v. Foster, 960 A.2d 160 (Pa. Super. 2008) (challenges to mandatory sentencing provisions implicate legality of sentence)