Com. v. Heath, A., Com. v. Heath, A. No. 2577 EDA 2015

In February 2014 a burning body was found in Jim Thorpe, PA; investigators recovered a Walmart bag with a receipt showing purchases earlier that morning. The victim was later identified as Angela Steigerwalt.
Walmart surveillance showed Anthony Heath purchasing lighter, lighter fluid, and a tote, and using Steigerwalt’s credit card to buy other items; her car was tracked via OnStar to North Carolina where police stopped it and arrested Heath.
Heath was interviewed multiple times in North Carolina and while being transported to Pennsylvania. He received Miranda warnings at some interviews, signed waivers, and ultimately made statements admitting he strangled Steigerwalt, placed her in a tote, set it on fire, and dropped/returned for the vehicle key fob.
Heath represented himself at trial; the Commonwealth introduced the victim’s husband’s key fob into evidence and relied on Heath’s statements. A jury convicted Heath of first-degree murder and related offenses; he was sentenced to life without parole plus additional prison time.
On appeal Heath challenged (1) denial of his motion to suppress his statements as involuntary/invalid Miranda waivers and caused by promises, and (2) admission of the key fob as irrelevant and unduly prejudicial. The Superior Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were Heath’s statements involuntary / were Miranda waivers invalid?	Commonwealth: statements were voluntary; waivers knowing, intelligent; surrounding circumstances made homicide purpose clear.	Heath: waivers invalid because officers only said questioning concerned the car; statements coerced by promises ("cooperate to graduate") and lengthy unrecorded interrogations.	Court: Affirmed suppression denial — totality shows voluntary, knowledgeable waivers; no coercive promise induced confession.
Was the victim’s husband’s key fob admissible?	Commonwealth: key fob corroborates Heath’s statements that the car used a fob and he dropped/recovered it; relevant.	Heath: key fob irrelevant or, if relevant, unfairly prejudicial / sentimental and inflaming.	Court: Key fob relevant and probative; not unduly prejudicial; admission was proper.

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda warning and waiver principles)
Commonwealth v. Paxton, 821 A.2d 594 (Pa. Super. 2003) (standards for voluntariness and waiver review)
Commonwealth v. Carr, 580 A.2d 1362 (Pa. Super. 1990) (awareness of the "transaction" suffices for waiver)
Commonwealth v. Peters, 373 A.2d 1055 (Pa. 1977) (confession induced by promise of immunity is involuntary)
Commonwealth v. Bergen, 142 A.3d 847 (Pa. Super. 2016) (standard for admissibility of evidence/relevance)
Commonwealth v. Foley, 38 A.3d 882 (Pa. Super. 2012) (rule on unfair prejudice under Pa.R.E. 403)