Com. v. Landis, W.
277 A.3d 1172
| Pa. Super. Ct. | 2022Background
- In 2009 William R. Landis Jr. was accused of killing his wife; police found her shot in a bedroom and a standoff later ensued in which Landis fired at officers before surrendering. Ballistics, DNA, autopsy (stippling showing close-range head wound), and witness calls were introduced at trial.
- Landis was convicted of first‑degree murder in 2013 and sentenced to life; a PCRA court later granted a new trial based on ineffective-assistance claims, which was affirmed on appeal; retrial on first‑degree murder was held in September 2020.
- At the 2020 trial the defense pursued diminished capacity/intoxication and presented Dr. Rotenberg; the Commonwealth presented rebuttal psychiatric testimony from Dr. O’Brien, who opined Landis could form intent and (erroneously) referred to pre‑event statements in investigative reports.
- The jury convicted Landis of first‑degree murder and he was sentenced to life on November 12, 2020. Landis moved post‑sentence for acquittal or, alternatively, a new trial on weight‑of‑evidence grounds, arguing Dr. O’Brien’s testimony was unreliable.
- The trial court granted a new trial, finding Dr. O’Brien’s testimony incompetent and concluding the jury was misled; the Commonwealth appealed and the Superior Court reversed, holding the trial court abused its discretion by substituting its credibility determination for the jury’s and failing to assess the evidence as a whole.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Landis) | Held |
|---|---|---|---|
| Whether Commonwealth’s concise statement preserved the weight‑of‑evidence challenge | Statement was sufficiently clear from context to allow review | Statement was too vague; claim waived | Not waived — concise statement was understandable and did not impede review |
| Whether the trial court abused its discretion in granting a new trial on weight grounds | Trial court improperly substituted its judgment for the jury by disregarding the record and focusing on one expert remark; the jury could weigh competing expert testimony | Trial court correctly found Dr. O’Brien’s testimony unreliable and therefore verdict against the weight of the evidence | Trial court abused discretion; Superior Court reversed and reinstated judgment of sentence |
| Whether Dr. O’Brien’s testimony was legally incompetent because it relied on an inaccurate factual assertion and lacked retained notes | Jury could discount any mistaken remark; report was provided in discovery; expert’s testimony still had an adequate factual basis | Inaccurate statement and missing notes rendered the opinion incompetent and prejudicial | Appellate court held the trial court erred to the extent it invalidated O’Brien’s opinion without assessing the opinion as a whole; competency issue not a basis the Commonwealth pressed on appeal |
| Whether evidence was sufficient to support first‑degree murder (as alternative to weight claim) | Evidence (multiple shots to vital areas, ballistics, DNA on weapon, consciousness of guilt) supported jury’s finding of specific intent | Contended intoxication/diminished capacity prevented specific intent | Superior Court implicitly affirmed sufficiency by reversing the new‑trial order and reinstating conviction |
Key Cases Cited
- Commonwealth v. Widmer, 744 A.2d 745 (Pa. 2000) (standard for weight‑of‑evidence review and limits on trial‑court acting as a thirteenth juror)
- Commonwealth v. Clay, 64 A.3d 1049 (Pa. 2013) (appellate standard for reviewing a trial court’s exercise of discretion on weight claims)
- Commonwealth v. Brown, 648 A.2d 1177 (Pa. 1994) (weight‑of‑evidence principles and trial‑court discretion)
- Commonwealth v. Rogers, 250 A.3d 1209 (Pa. 2021) (Rule 1925(b) concise‑statement purpose and waiver analysis)
- Commonwealth v. Laboy, 936 A.2d 1058 (Pa. 2007) (review where trial court addressed brief Rule 1925(b) claim on the merits)
- Commonwealth v. Farquharson, 354 A.2d 545 (Pa. 1976) (deference to trial judge who saw and heard witnesses when reviewing credibility)
- Sullivan v. Werner Co., 253 A.3d 730 (Pa. Super. 2021) (expert opinion must have adequate factual basis; inaccurate facts do not automatically render opinion incompetent)