Com. v. Knight, J.
379 WDA 2017
| Pa. Super. Ct. | Nov 29, 2017Background
- On April 10, 2014, two masked gunmen entered Apartment 17H in Hawkins Village; Jake Knight was later identified by multiple occupants as one of the intruders who shot and mortally wounded Lee Williams.
- Two firearms were recovered under the rear steps of Building 35 shortly after the shooting; one was a Glock .357 later linked to a shell casing found at the scene.
- Witnesses (Francis, Jones, Howard) identified Knight at trial; Knight was arrested at his residence (35B), where black clothing and a neoprene half‑mask were recovered and his jeans tested positive for gunshot residue.
- The jury convicted Knight of second‑degree murder, conspiracy to commit burglary, burglary, and three counts of recklessly endangering another person; he received a life sentence plus concurrent terms.
- On appeal Knight raised three claims: (1) trial court erred in finding two witnesses competent / he did not waive competency objection; (2) trial court allowed improper prior‑bad‑act evidence (March 30 shootout) in violation of Pa.R.E. 404(b); (3) trial court improperly denied discovery of the TrueAllele source code used in DNA mixture analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Witness competency (Jones & Francis) waived | Commonwealth: trial record shows witnesses testified and were cross‑examined without contemporaneous competency objection; waiver. | Knight: competence challenge raised in pretrial motion; court should have ruled and order preserved issue. | Waived — no definitive pretrial ruling in record; Knight failed to renew objection at trial and fully cross‑examined witnesses. |
| Admission of prior bad‑act evidence (March 30 shootout) | Commonwealth: evidence relevant to identity and plan; Glock from March incident matched casing class and was linked to March event; jury instructed on limited use. | Knight: prior‑act evidence improperly suggested bad character and invited impermissible inference of propensity under Pa.R.E. 404(b). | Admitted for limited purpose of identity — probative value outweighed prejudice and jury received limiting instruction. |
| TrueAllele source‑code discovery | Commonwealth: TrueAllele reliability can be tested and challenged without source code; expert thoroughly cross‑examined; code not material to defense. | Knight: source code is necessary to test and confront DNA mixture analysis and thus material discovery. | Denied — trial court did not abuse discretion; source code not shown material or reasonably required and Knight had full opportunity to cross‑examine the expert. |
Key Cases Cited
- Commonwealth v. Akrie, 159 A.3d 982 (Pa. Super. 2017) (standard for appellate review of evidentiary rulings)
- Commonwealth v. McGriff, 160 A.3d 863 (Pa. Super. 2017) (when a pretrial ruling definitively resolves an objection, renewal at trial is unnecessary)
- Commonwealth v. McKinley, 123 A.2d 735 (Pa. Super. 1956) (competency objections ordinarily must be raised at time witness is offered; failure to object waives claim)
- Commonwealth v. Lockcuff, 813 A.2d 857 (Pa. Super. 2002) (Rule 404(b) permits prior acts for non‑propensity purposes such as identity and plan)
- Commonwealth v. Solano, 129 A.3d 1156 (Pa. 2015) (when prior‑act evidence is admitted, defendant is entitled to limiting instruction)
- Commonwealth v. Foley, 38 A.3d 882 (Pa. Super. 2012) (TrueAllele source code not required for reliability testing; reliability can be determined without disclosure of source code)
- Commonwealth v. Snell, 811 A.2d 581 (Pa. Super. 2002) (discovery of items under Pa.R.Crim.P. 573 requires showing materiality and reasonableness)
- Commonwealth v. Wilson, 602 A.2d 1290 (Pa. 1992) (Confrontation Clause guarantees opportunity for effective cross‑examination, not unfettered access to all materials)