Com. v. Satchell, D.
2005 EDA 2015
Pa. Super. Ct.Nov 10, 2016Background
- On May 20, 2007 a gunfight in North Philadelphia killed Ronald Kennel and injured Charlene McDonald; multiple shooters fired different caliber weapons in a crowded street.
- Witnesses placed David Satchell at the scene armed and firing; he was later identified by at least one eyewitness and arrested in December 2007.
- Satchell was convicted by jury of third‑degree murder, conspiracy, aggravated assault, and PIC, and sentenced to an aggregate term of 29 to 62 years; direct appeals were denied.
- Satchell filed a PCRA petition asserting ineffective assistance of trial and appellate counsel for failure to obtain an involuntary manslaughter jury instruction.
- Trial counsel requested an involuntary manslaughter instruction at trial and preserved the claim when the court declined; appellate counsel did not raise the issue on direct appeal.
- The PCRA court dismissed the petition without an evidentiary hearing; the Superior Court reversed and remanded for a hearing on appellate counsel’s effectiveness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was arguable merit to an involuntary manslaughter instruction | Satchell: evidence (witnesses who saw him fire into a crowd) supported involuntary manslaughter and the instruction should have been given | Commonwealth: Satchell’s own testimony denying he fired means no evidence supports the instruction; cited cases where defendants admitted culpable conduct | Court: There was arguable merit—evidence from witnesses could support involuntary manslaughter and the instruction was properly requested |
| Whether trial counsel was ineffective for failing to obtain the instruction | Satchell: counsel should have more forcefully invoked controlling authority (e.g., Draxinger) to secure the instruction | Commonwealth: counsel did request the instruction and preserved the issue, so performance was reasonable | Court: Trial counsel was not ineffective—he requested the charge, argued a basis, and noted exception when denied |
| Whether appellate counsel was ineffective for omitting the claim on direct appeal | Satchell: appellate counsel’s omission of an arguably meritorious, preserved claim was ineffective assistance | Commonwealth: omission may have been strategic; record lacks counsel’s explanation | Held: Remanded for an evidentiary hearing to determine whether appellate counsel had a reasonable basis and whether prejudice resulted |
| Whether PCRA court properly dismissed without a hearing | Satchell: dismissal was improper because the record was incomplete as to appellate counsel’s reasons | Commonwealth: dismissal appropriate because trial counsel preserved the claim and no arguable merit (as PCRA court found) | Held: PCRA court erred by dismissing without a hearing on appellate counsel’s effectiveness; remand ordered |
Key Cases Cited
- Commonwealth v. Williams, 863 A.2d 505 (Pa. 2004) (standard for proving ineffective assistance of counsel)
- Commonwealth v. Pierce, 786 A.2d 203 (Pa. 2001) (three‑prong test for counsel ineffectiveness)
- Commonwealth v. Charleston, 94 A.3d 1012 (Pa. Super. 2014) (defendants entitled to requested instructions supported by the whole evidence)
- Commonwealth v. Browdie, 671 A.2d 668 (Pa. 1996) (trial court must instruct only where offense is an issue and evidence reasonably supports the verdict)
- Commonwealth v. Draxinger, 498 A.2d 963 (Pa. Super. 1985) (involuntary manslaughter instruction required if any version of the evidence supports it)
- Commonwealth v. McCloskey, 656 A.2d 1369 (Pa. Super. 1995) (application of involuntary manslaughter instruction where defendant’s account admitted reckless conduct)