Com. v. Heagy, T.
692 MDA 2017
| Pa. Super. Ct. | Dec 8, 2017Background
- On Sept. 26–27, 2015, Tyler Heagy assaulted his intimate partner, Kristine Haduck, at/near a bar: he repeatedly beat her, dragged her, threw her into a pond and pinned her head underwater; bystanders intervened and police arrested Heagy.
- A March 2014 prior incident was admitted at trial under Pa.R.E. 404(b): Heagy allegedly kicked in Haduck’s door while intoxicated, pushed her, and punched another man present.
- A jury convicted Heagy of attempted murder, aggravated assault, two counts of simple assault, and recklessly endangering another person on March 1, 2017.
- On March 13, 2017 Heagy was sentenced to an aggregate term of 8 to 22 years’ imprisonment; the court included a special condition barring contact with Haduck and her family, including Heagy’s biological daughter.
- Heagy appealed, arguing (1) the 404(b) evidence was more prejudicial than probative and improperly showed propensity, and (2) the special sentencing condition prohibiting contact with his daughter was illegal.
- The Superior Court affirmed the convictions and sentence except it vacated the special parole-related contact condition as beyond the trial court’s authority.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of 404(b) evidence (prior 2014 assault) | Commonwealth: prior incident shows motive, intent, malice, ill will, and common scheme (jealousy, escalation when intoxicated) — probative value outweighs prejudice | Heagy: prior act was propensity evidence, highly prejudicial and should have been excluded under Pa.R.E. 404(b) | Court: Admissible — logical connection and common plan established; probative value outweighed prejudice; no abuse of discretion |
| Legality of special sentencing condition barring contact with daughter | Commonwealth/trial court: condition imposed to protect victim and family (but concede court lacked authority over parole conditions) | Heagy: condition illegal because the Board of Probation and Parole exclusively sets parole conditions for sentences over two years | Court: Vacated that special condition as the trial court lacked authority to impose parole conditions; remainder of sentence affirmed |
Key Cases Cited
- Commonwealth v. Wattley, 880 A.2d 682 (Pa. Super. 2005) (standard of review for evidentiary rulings and abuse of discretion)
- Commonwealth v. Robinson, 864 A.2d 460 (Pa. 2004) (other-crimes evidence admissible to show common plan, scheme, or design)
- Commonwealth v. Arrington, 86 A.3d 831 (Pa. 2014) (framework for admissibility of prior acts to show common scheme and balancing probative value vs. prejudice)
- Commonwealth v. Preston, 904 A.2d 1 (Pa. Super. 2006) (appellate waiver when necessary trial transcripts are not provided)
- Commonwealth v. Mears, 972 A.2d 1210 (Pa. Super. 2009) (trial court sentence conditions affecting parole are advisory when sentence exceeds two years)
- Commonwealth v. Coulverson, 34 A.3d 135 (Pa. Super. 2011) (Board of Probation and Parole has exclusive authority to set parole conditions)