Com. v. Knight, D.
Com. v. Knight, D. No. 2540 EDA 2015
| Pa. Super. Ct. | Apr 18, 2017Background
- Defendant Donald Knight was convicted by a judge of attempted burglary, attempted criminal trespass (breaking into a structure), possession of an instrument of crime, and criminal mischief; sentenced to 9–23 months incarceration plus 3 years reporting probation on the attempted burglary count.
- Police responded around 2:30 a.m. to a convenience store at 100 E. Coulter St.; observed a metal-grate rear door "pried away," a crowbar on a nearby ledge, and photographic evidence of door/wall damage.
- Officer Benson found Knight at 107 E. Coulter St. hiding on a porch in a black hoodie, crouched behind a grill with gloves in his pocket, a small flashlight, and another crowbar within arm’s reach.
- Knight gave a post-Miranda written statement admitting he was "playing around," that he did pry/drop something, did not enter or take anything, and acknowledged handling the crowbar while wearing gloves; the statement was admitted at trial.
- Knight appealed, arguing the trial court violated the corpus delicti rule by (1) admitting his statement without first proving a crime had occurred and (2) improperly relying on the statement when corpus delicti had not been proven beyond a reasonable doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court properly admitted Knight’s post‑Miranda statement under the corpus delicti rule | Commonwealth: evidence (damaged door, crowbar, photos) established by preponderance that a crime occurred, so statement admissible | Knight: no corpus of the crime had been shown; confession admitted prematurely | Held: Admission proper — preponderance satisfied by physical damage, crowbar, photos |
| Whether corpus delicti was proven beyond a reasonable doubt so the factfinder could consider Knight’s statement for guilt | Commonwealth: totality of circumstances (proximity, hiding, attire, gloves, flashlight, crowbar) proved attempted burglary beyond reasonable doubt | Knight: even if admitted, statement should not have been used because corpus delicti not established to criminal standard | Held: Proven beyond a reasonable doubt; court could consider statement substantively |
| Whether trial court abused its discretion in evidentiary rulings on corpus delicti | Commonwealth: trial court properly exercised discretion relying on record and photos | Knight: trial court misapplied law and over-relied on confession-related evidence | Held: No abuse of discretion; appellate court affirms deference to trial court |
| Whether conviction rested solely on confession such that corpus delicti rule required exclusion | Commonwealth: independent physical and circumstantial evidence existed apart from the confession | Knight: confession was pivotal and could have generated conviction absent independent proof | Held: Independent evidence sufficed; conviction not based solely on confession |
Key Cases Cited
- Commonwealth v. Young, 904 A.2d 947 (Pa. Super. 2006) (explains two-step corpus delicti standard: preponderance to admit, beyond a reasonable doubt to consider)
- Commonwealth v. Rivera, 828 A.2d 1094 (Pa. Super. 2004) (corpus delicti rule and admission/consideration framework)
- Commonwealth v. Herb, 852 A.2d 356 (Pa. Super. 2004) (standard of review for evidentiary rulings; abuse of discretion)
- Commonwealth v. Hernandez, 39 A.3d 409 (Pa. Super. 2012) (application of corpus delicti analysis and deference to trial court)