Com. v. Jones, D.
Com. v. Jones, D. No. 105 MDA 2016
| Pa. Super. Ct. | Feb 24, 2017Background
- Appellant Daequahn Jones was tried for the fatal shooting of Na’Gus Griggs; jury convicted him of third-degree murder and sentenced to 18–40 years.
- Commonwealth sought to introduce: (1) a computer-generated crime-scene map/trajectory analysis produced one week before trial; and (2) a color autopsy photograph showing the entry wound and surrounding "pseudo-stippling."
- Defense moved in limine to suppress the map for lateness/prejudice and moved for mistrial (and to bar the color autopsy photo) after the photo was momentarily and accidentally displayed during trial.
- Eyewitnesses testified Appellant fired the first shots from the sidewalk; forensic trajectory analysis and autopsy (pseudo-stippling) supported that shots came from outside the victim’s car, undermining Appellant’s self-defense claim.
- The trial court admitted both the map and the color autopsy photograph after balancing relevance and prejudice; denied mistrial; jury convicted.
Issues
| Issue | Commonwealth / Plaintiff Argument | Appellant Argument | Held |
|---|---|---|---|
| Admissibility of computer-generated trajectory map produced one week before trial | Map was relevant, probative, and not unduly prejudicial; defense had time to consult expert | Late production prejudiced defense and warranted suppression | Trial court did not abuse discretion; denial affirmed (no showing of prejudice) |
| Motion for mistrial and color autopsy photo admissibility after accidental display | Photo was relevant to disprove self-defense (shows entry, pseudo-stippling); color needed to distinguish wounds from skin markers | Momentary flash was inflammatory; color photo unduly prejudicial and black-and-white alternative should be required | No mistrial; photo admissible after Tharp balancing — evidentiary need outweighed prejudice; curative instruction sufficient |
| Sufficiency of evidence to disprove self-defense (third-degree murder) | Eyewitnesses and forensic evidence showed Appellant fired first and shots originated outside car; Commonwealth disproved self-defense beyond reasonable doubt | Evidence (GSR in car, some witnesses saying shots came from car) left reasonable doubt about who fired first | Jury verdict upheld; evidence sufficient to disprove self-defense and support third-degree murder conviction |
Key Cases Cited
- Commonwealth v. Hoover, 107 A.3d 723 (Pa. 2014) (standard for reviewing evidentiary rulings/abuse of discretion)
- Commonwealth v. Laird, 988 A.2d 618 (Pa. 2010) (abuse-of-discretion requires manifest unreasonableness)
- Commonwealth v. Sherwood, 982 A.2d 483 (Pa. 2009) (abuse-of-discretion definition)
- Commonwealth v. Travaglia, 28 A.3d 868 (Pa. 2011) (standard for mistrial review)
- Commonwealth v. Tharp, 830 A.2d 519 (Pa. 2003) (two-step test for inflammatory photographs: relevance then necessity vs. prejudice)
- Commonwealth v. Hubbard, 372 A.2d 687 (Pa. 1977) (when a photograph is inflammatory)
- Commonwealth v. Lewis, 567 A.2d 1376 (Pa. 1989) (blood alone does not require finding photograph inflammatory)
- Commonwealth v. Pezzeca, 749 A.2d 968 (Pa. Super. 2000) (trial court discretion re: curative instructions)
- Commonwealth v. Flor, 998 A.2d 606 (Pa. 2010) (presumption that jury follows instructions)
- Commonwealth v. Truong, 36 A.3d 592 (Pa. Super. 2012) (sufficiency-of-evidence standard)
- Commonwealth v. Smith, 97 A.3d 782 (Pa. Super. 2014) (burden to disprove self-defense placed on Commonwealth)