Com. v. Rodriguez, M., 210 EDA 2017

Background

On Feb 9, 2013, a patron (Damien Robinson) was shot at Eddie G’s bar in Easton; he later died. Police recovered casings, bullets, a broken cell phone, a sweatshirt, and a bag of suspected marijuana from the back room.
Eyewitness Mike King (a bouncer) testified he saw Rodriguez with a gun and heard three shots; he initially withheld ID from police and first lied to the grand jury but later identified Rodriguez. Bartender Jennifer Delgado later testified and admitted she initially misled police and received leniency/immunity for cooperation.
DNA testing linked Rodriguez to the bag of marijuana and as a major contributor on the recovered cell phone; casings/bullets were all fired from the same firearm but casings lacked testable DNA.
Rodriguez was arrested, tried by jury (Feb 1–5, 2016), convicted of first-degree murder, and sentenced to life without parole. He filed post-sentence motions and appealed after a procedural delay caused by a clerk’s error.
On appeal Rodriguez raised six issues: weight of the evidence, disclosure of witness contact info, admission of testimony about assaults on a witness, hearsay/grand jury testimony issues, refusal to instruct jury on penalty for murder, and Eighth Amendment/Miller challenge to life without parole.

Issues

Issue	Rodriguez's Argument	Commonwealth's Argument	Held
Weight of the evidence (one-witness ID)	Verdict unreliable—based on a single eyewitness (King), inconsistent ID, witnesses had motives to lie, DNA only places Rodriguez at scene earlier	Jury could credit King; additional circumstantial/DNA evidence corroborated ID; credibility for jury	Denied — trial court decision not an abuse of discretion; verdict did not shock conscience (weight review standard applied)
Disclosure of witness contact info	Trial court erred by not ordering addresses/phone numbers for ~56 witnesses; court’s in-court meeting was inadequate and prevented private defense interviews	Commonwealth withheld contact info for witness safety; court provided names and facilitated courthouse interviews/subpoenas	Denied — court balanced safety and defense needs; no abuse of discretion under Pa.R.Crim.P. 573
Admission of Delgado’s testimony about later assaults/killing	Testimony constituted inadmissible prior-bad-acts evidence and prejudicial	No contemporaneous objection at trial; issue waived	Waived — appellant failed to object at trial, so appellate review barred
Hearsay/grand jury testimony read at trial	Detective’s statements and prosecutor’s reading were impermissible hearsay	Transcript excerpts were grand jury testimony read by agreement; no objection was made at trial	Waived — appellant expressly agreed at trial to reading; cannot raise on appeal
Jury instruction on penalty for first-degree murder	Jury should have been told the mandatory penalty to evaluate alternate suspects’ motive to lie	Punishment is for the court; juries decide guilt only; penalty info could improperly influence jury	Denied — punishment is court’s domain; not an appropriate jury instruction
Life without parole sentence under Miller (Eighth Amendment)	Mandatory LWOP violates Miller because Rodriguez’s youth/immaturity made him like a juvenile	Miller applies only to offenders under 18 at the time of the crime; Rodriguez was 18 at the time	Denied — Miller inapplicable; sentence legally authorized for an 18‑year‑old

Key Cases Cited

Commonwealth v. Capaldi, 112 A.3d 1242 (Pa. 2015) (timing of appeal when post‑sentence motions filed)
Commonwealth v. Clay, 64 A.3d 1049 (Pa. 2013) (standard for appellate review of weight‑of‑the‑evidence claims)
Commonwealth v. Washington, 63 A.3d 797 (Pa. Super. 2013) (trial court discretion in disclosure of eyewitness contact information)
Commonwealth v. Jordan, 125 A.3d 55 (Pa. Super. 2015) (balancing witness safety and defense access under Rule 573)
Commonwealth v. Hood, 872 A.2d 175 (Pa. Super. 2005) (no mandatory disclosure of witness identifying info under Rule 573)
Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (mandatory LWOP for offenders under 18 unconstitutional)