Com. v. Robinson, C.
547 EDA 2016
| Pa. Super. Ct. | Oct 17, 2017Background
- On Sept. 25, 2013, Charles Robinson allegedly rode by on a bicycle and shot Raheem Williams; Williams died from a chest wound.
- Robert Mack gave a written statement to police the next day identifying Robinson as the shooter, then later recanted at preliminary hearing and trial, claiming drug use and coercive police treatment.
- Mack’s initial statement was corroborated by Raheem’s mother (who said Mack visited and identified Robinson the day after the shooting) and by Rashon Miller (who saw the victims running immediately after the shots).
- Robinson called Officer Bryan Turner days after the shooting suggesting he had shot the wrong person, said he would surrender, then went into hiding; he was arrested ~6 months later.
- During deliberations the jury requested and the court allowed prior written statements of Mack, Miller, and Turner into the jury room (redacted by agreement).
- Jury convicted Robinson of first-degree murder and sentenced him to life without parole; he appealed raising sufficiency/weight of evidence, jury access to statements, cross-examination of character witnesses, and prosecutorial misconduct.
Issues
| Issue | Appellant's Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Sufficiency: Was evidence adequate to support first-degree murder? | Mack’s testimony was inherently unreliable and central; conviction rests on conjecture. | Mack’s contemporaneous statement was corroborated by other witnesses and Robinson’s conduct, supporting guilt beyond a reasonable doubt. | Affirmed: viewing evidence in Commonwealth’s favor, sufficiency satisfied. |
| Weight: Was verdict against weight of the evidence? | Recantation and inconsistent testimony rendered verdict shocking to justice. | Jury credibility determinations are controlling; corroborating evidence and flight undermined weight claim. | Affirmed: trial court did not abuse discretion denying a new trial. |
| Jury access to prior statements: Did allowing certain witness statements in jury room unfairly emphasize prosecution evidence? | Sending prior statements (without recantations/cross-examination) skewed deliberations and prejudiced defense. | Statements were admitted as substantive evidence; jury requested them to assess credibility; court acted within discretion and redacted by agreement. | Affirmed: court did not abuse discretion under Pa.R.Crim.P. 646. |
| Cross-examination & closing/prosecutorial conduct: Were character witness questioning and prosecutor’s remarks improper or prejudicial? | Prosecutor improperly impeached character witnesses with fugitive status, vouched for witnesses, and used inflammatory gestures; defense character was undermined. | Questions about fugitive status tested the character testimony and referenced evidence already introduced; closing comments were fair responses, not personal vouching, and within reasonable latitude. | Affirmed: cross-examination and closing argument were permissible; no prosecutorial misconduct warranting new trial. |
Key Cases Cited
- Commonwealth v. Karkaria, 625 A.2d 1167 (Pa. 1993) (testimony so inherently unreliable can render verdict mere conjecture)
- Commonwealth v. Sanchez, 36 A.3d 24 (Pa. 2011) (intent to kill may be inferred from use of a deadly weapon on a vital part)
- Commonwealth v. Parker, 104 A.3d 17 (Pa. Super. 2014) (prior inconsistent or consistent witness statements admitted substantively may be sent to jury during deliberations)
- Commonwealth v. LaCava, 666 A.2d 221 (Pa. 1995) (standard for prosecutorial misconduct is whether conduct deprived defendant of fair trial)
- Commonwealth v. Pierce, 645 A.2d 189 (Pa. 1994) (prosecutor’s abuse of position warrants relief when it renders factfinder incapable of fair weighing of evidence)