Com. v. Jackson, D.
1607 EDA 2016
| Pa. Super. Ct. | Jan 10, 2018Background
- On Dec. 1–2, 2014, Derrick Jackson robbed two men at shotgun-point and, later that night, shot and killed Lori Sheridan in her home; motive evidence indicated she owed him drug money.
- Probation officers visited Jackson Dec. 2, 2014; they observed a plastic bag in his pocket, sought entry, obtained consent to search, and discovered a shotgun, shells, and heroin behind a shed; Jackson was arrested for violating probation.
- Jackson gave multiple statements to police (Miranda warnings given before the first and again before the fourth); in the final statement he admitted killing Sheridan but claimed it was accidental.
- Jackson was charged with first‑degree murder, two counts of armed robbery, and related offenses; a jury convicted him of first‑degree murder and other charges, and the trial court sentenced him to life without parole.
- Pretrial, Jackson sought suppression of statements and physical evidence (various pro se and counseled motions); the trial court denied suppression after two hearings; Jackson also raised voluntary‑intoxication/diminished‑capacity at trial.
- On appeal, Jackson argued (1) suppression rulings were erroneous, (2) the murder verdict was against the weight of the evidence due to intoxication, and (3) his life sentence was unconstitutional for a youthful offender; the Superior Court affirmed.
Issues
| Issue | Jackson's Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Validity of search/consent and suppression of physical evidence | Search and arrest were unlawful; evidence and statements should be suppressed | Probation officers obtained consent to enter; search yielded gun, shells, heroin; suppression properly denied | Trial court's factual findings supported by record; suppression denial affirmed |
| Admissibility/voluntariness of statements (Miranda/delay/coercion) | Statements involuntary/obtained without proper Miranda waiver and by coercion/delay | Officers gave Miranda warnings before first and repeated before fourth; statements voluntary | Suppression of statements properly denied; Miranda warnings adequate and statements admissible |
| Weight of the evidence / diminished capacity (voluntary intoxication) | Jackson was under marijuana/PCP enough to negate specific intent to kill; verdict shocks conscience | Commonwealth presented rebuttal expert and other evidence showing capability for premeditation and motive; jail letters showed consciousness of guilt | Jury credited Commonwealth; evidence supported specific intent; weight claim denied |
| Constitutionality/reasonableness of life-without-parole sentence for youthful offender | Life without parole fails to consider youth and rehabilitation potential; unconstitutional | Issue not developed on appeal | Unraised/undeveloped on appeal; not addressed further (claim waived) |
Key Cases Cited
- Commonwealth v. Lord, 719 A.2d 306 (Pa. 1998) (Rule 1925(b) specificity and waiver principles)
- Commonwealth v. Woodard, 129 A.3d 480 (Pa. 2015) (standard of review for suppression appeals)
- Commonwealth v. Galvin, 985 A.2d 783 (Pa. 2009) (de novo review on legal questions in suppression rulings)
- Commonwealth v. Poplawski, 130 A.3d 697 (Pa. 2015) (scope of review limited to suppression hearing evidence)
- In re L.J., 79 A.3d 1073 (Pa. 2013) (exclusion of trial evidence from suppression review)
- Commonwealth v. Hutchinson, 25 A.3d 277 (Pa. 2011) (limits of diminished‑capacity defense for voluntary intoxication)
- Commonwealth v. Blakeney, 946 A.2d 645 (Pa. 2008) (requirement that intoxication overwhelm faculties to negate specific intent)
- Commonwealth v. Houser, 18 A.3d 1128 (Pa. 2011) (standard for appellate review of weight claims)
- Commonwealth v. Smith, 955 A.2d 391 (Pa. Super. 2008) (Rule 1925(b) and meaningful review; waiver when trial court must guess issues)
- Commonwealth v. Williams, 959 A.2d 1252 (Pa. Super. 2008) (vagueness in concise statement leads to waiver)