Com. v. Hendricks, M.
Com. v. Hendricks, M. No. 234 EDA 2016
| Pa. Super. Ct. | Jul 11, 2017Background
- In April 2007 David Rivera was shot and killed; Clyde Lont later pled guilty for his role; Matthew Hendricks was tried by a jury and convicted of third-degree murder and acquitted of conspiracy.
- Evidence at trial included eyewitness testimony placing Hendricks near the Chrysler 300, cell‑phone records showing communications among Rivera, Lont, Hendricks and others, fingerprints linking Hendricks to the vehicle, and Gordon’s testimony describing admissions by Lont.
- Hendricks was sentenced to 20–40 years (May 3, 2011); post‑verdict motions and direct appeal were denied, and the Pennsylvania Supreme Court denied allowance of appeal.
- In a counseled PCRA petition Hendricks alleged (1) a Brady violation based on undisclosed statements Janelle Gordon purportedly relayed about Lont exculpating Hendricks, and (2) trial counsel ineffectiveness for failing to challenge alleged inconsistent verdicts.
- The PCRA court held hearings, credited Commonwealth witnesses over Gordon, rejected a Brady violation, found sufficient evidence supported the third‑degree murder conviction, denied ineffective‑assistance relief, and dismissed the PCRA petition. This Court affirmed on appeal.
Issues
| Issue | Plaintiff's Argument (Hendricks) | Defendant's Argument (Commonwealth / Court) | Held |
|---|---|---|---|
| Brady violation — failure to disclose exculpatory/impeachment evidence | Gordon would have testified that Lont told her Hendricks "had nothing to do with" the killing; prosecution suppressed that information | Commonwealth witnesses testified Gordon never told them Lont made that statement; prosecution instructed Gordon not to mention certain statements due to a motion in limine; trial court credited prosecution witnesses | No Brady violation — court credited Commonwealth witnesses; Gordon’s PCRA testimony discredited, so nothing favorable was shown to have been suppressed |
| Ineffective assistance re: inconsistent verdicts / sufficiency | Counsel failed to raise inconsistent‑verdict claim (acquittal on conspiracy vs. conviction for third‑degree murder) on post‑sentence motions or appeal | Verdicts can be inconsistent but permissible; Commonwealth proceeded on co‑conspirator and accomplice theories and the evidence supported third‑degree murder | No relief — court held (1) inconsistent verdicts permitted and (2) sufficiency supported conviction, so the ineffectiveness claim lacked arguable merit |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution must disclose favorable, material evidence)
- Commonwealth v. Lambert, 884 A.2d 848 (Pa. 2005) (elements of Brady claim)
- Commonwealth v. Talbert, 129 A.3d 536 (Pa.Super. 2015) (inconsistent verdicts permissible; focus on sufficiency)
- Commonwealth v. Ligons, 971 A.2d 1125 (Pa. 2009) (three‑part test for PCRA ineffectiveness claims)
- Commonwealth v. Spotz, 18 A.3d 244 (Pa. 2011) (presumption of counsel effectiveness)
- Commonwealth v. Pagan, 950 A.2d 270 (Pa. 2008) (accomplice liability and proving intent by circumstantial evidence)
- Commonwealth v. Messersmith, 860 A.2d 1078 (Pa.Super. 2004) (assessing prejudice from juror exposure to extraneous information)
- Commonwealth v. Bracey, 831 A.2d 678 (Pa.Super. 2003) (mistrial is extreme remedy; curative instruction may suffice)