Com. v. Satchell, D.
2005 EDA 2015
| Pa. Super. Ct. | Nov 10, 2016Background
- Appellant David Satchell was convicted of third-degree murder after participating in a daytime gun battle on a crowded public street; appellant claimed he was only present and did not fire a weapon.
- Trial counsel requested an involuntary manslaughter jury instruction; the trial court denied the request and counsel noted an exception.
- On direct appeal the Superior Court upheld sufficiency of the evidence for third‑degree murder.
- Appellant filed a PCRA petition claiming appellate counsel was ineffective for failing to raise the trial court’s refusal to instruct on involuntary manslaughter on direct appeal.
- The Superior Court majority found arguable merit to the ineffective-assistance claim and remanded for the PCRA court to decide reasonable basis and prejudice; the dissent (Stevens, P.J.E.) would affirm the PCRA dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether involuntary manslaughter instruction was required | Satchell: trial court erred by refusing the instruction; evidence could support lesser-included verdict | Commonwealth: facts showed malice sufficient for third-degree murder, not mere recklessness or gross negligence | Dissent: no, instruction not required; evidence supported third-degree murder and involuntary manslaughter was not an issue |
| Whether appellate counsel was ineffective for not raising the instruction on direct appeal | Satchell: appellate counsel should have raised the trial court’s omission as an appellate claim | Commonwealth: appellate counsel was not ineffective because the underlying claim lacks arguable merit | Majority: found arguable merit and remanded; Dissent: no arguable merit, so no ineffectiveness |
| Whether appellant met PCRA burden to show prejudice from appellate counsel’s omission | Satchell: asserted prejudice and requested an evidentiary hearing | Commonwealth: appellant failed to develop prejudice argument | Held (Dissent): appellant failed to meaningfully argue prejudice; remand/hearing unnecessary |
| Whether remand for evidentiary hearing on PCRA ineffective-assistance claim was required | Satchell: remand for hearing to resolve reasonable basis and prejudice | Commonwealth: no hearing needed absent arguable merit or developed prejudice showing | Held: Majority ordered remand; Dissent would affirm PCRA dismissal, refusing remand |
Key Cases Cited
- Commonwealth v. Baker, 24 A.3d 1006 (Pa. Super. 2011) (standard and deference for jury instruction review)
- Commonwealth v. McCloskey, 656 A.2d 1369 (Pa. Super. 1995) (three-part test for involuntary manslaughter instruction)
- Commonwealth v. Polimeni, 378 A.2d 1189 (Pa. 1977) (distinguishing involuntary manslaughter and culpable mental states)
- Commonwealth v. DiStefano, 782 A.2d 574 (Pa. Super. 2001) (discussion of malice and third-degree murder)
- Commonwealth v. Steele, 961 A.2d 786 (Pa. 2008) (appellant must separately develop each prong of ineffectiveness claim)