Com. v. Rawlings, B.
1597 EDA 2015
| Pa. Super. Ct. | Nov 17, 2016Background
- On Dec. 25–26, 2012 a woman was abducted from her car in Upper Darby, PA; three men (Jones, Matthews, Rawlings) forced her to perform sexual acts and Rawlings vaginally raped her according to her testimony.
- The victim identified Jones and Matthews at a show‑up; police later showed a black‑and‑white JNET photo array in which the victim identified Rawlings the next day.
- Police executed warrants at Rawlings’s home, recovered a backpack, mask, and gloves, and later recovered the gun after Rawlings led officers to its hiding place; Rawlings gave a signed statement admitting involvement.
- Jones and Matthews (both juveniles at the time) pled guilty and testified for the Commonwealth; their statements and the victim’s ID and Rawlings’s statement were central evidence at trial.
- Rawlings was convicted by a jury of rape, robbery, kidnapping, conspiracy, and related counts; sentenced to an aggregate 25–50 years; appealed denial of suppression motions, sufficiency/weight challenges, and a Brady claim.
Issues
| Issue | Commonwealth's Argument | Rawlings's Argument | Held |
|---|---|---|---|
| Whether the pretrial photo array was unduly suggestive, requiring suppression of the out‑of‑court ID | Photo array was randomly generated via JNET with similar‑looking men; victim made an unprompted, positive ID | Array was suggestive because Rawlings was the only person wearing a hooded sweatshirt matching what victim described | Court: Array not unduly suggestive; no substantial likelihood of misidentification; suppression denied |
| Whether Rawlings’s confession was involuntary and should be suppressed | Interrogation lasted ~1 hour; Miranda warnings given and waived; Rawlings was coherent, not restrained, not impaired | Interrogation was coercive: he was 19, forcibly removed from home, pressured by detectives, threatened, and denied counsel | Court: Confession voluntary under totality of circumstances; waiver knowing; suppression denied |
| Whether evidence was sufficient to prove Rawlings was the third attacker (and related convictions) | Victim’s photo and in‑court ID, co‑defendants’ statements, Rawlings’s signed statement, and his leading police to the gun provide overwhelming proof | Identification tainted by suggestive array; confession involuntary; co‑defendants had motives to lie; lack of Rawlings DNA and missing sweatshirt undermine proof | Court: Evidence sufficient; reasonable inferences support verdict; circumstantial gaps do not require acquittal |
| Whether the Commonwealth violated Brady by withholding a Victim Impact Statement allegedly containing impeaching material (ejaculation statement) | Commonwealth disputed materiality and there is no record evidence it withheld the statement; statement not in certified record so appellate review impossible | Statement contained impeaching evidence (victim said assailant ejaculated) that was favorable and material and was not produced at trial | Court: Brady claim rejected—appellant failed to include the statement in the certified record and failed to show it was in Commonwealth’s control/materially withheld |
Key Cases Cited
- Commonwealth v. DeJesus, 860 A.2d 102 (Pa. 2004) (photo‑array suggestiveness assessed under totality of circumstances)
- Commonwealth v. Burton, 770 A.2d 771 (Pa. Super. 2001) (variance among photos does not automatically require suppression)
- Commonwealth v. Fisher, 769 A.2d 1116 (Pa. 2001) (photos are acceptable if suspect’s picture does not stand out)
- Commonwealth v. Nester, 709 A.2d 879 (Pa. 1998) (voluntariness of confession judged by totality of circumstances)
- Commonwealth v. Gonzalez, 109 A.3d 711 (Pa. Super. 2015) (sufficient circumstantial evidence can sustain conviction)
- Commonwealth v. Lyons, 79 A.3d 1053 (Pa. 2013) (standard for weight‑of‑evidence review)
- Commonwealth v. Antidormi, 84 A.3d 736 (Pa. Super. 2014) (elements of Brady claim explained)