Com. v. Snyder, W.
Com. v. Snyder, W. No. 1933 MDA 2016
| Pa. Super. Ct. | Jul 27, 2017Background
- On April 5, 2015, William Joseph Snyder strangled his wife, hid her body, and then fabricated ransom and overdose stories over several days before admitting the killing to police.
- Snyder pled guilty to third-degree murder, abuse of a corpse, two counts of tampering/fabricating physical evidence, and unsworn falsification pursuant to a plea agreement that limited exposure but left concurrency/consecutiveness to the court.
- The agreed standard-range guidelines for murder were 72 months to the statutory limit (40 years aggregate cap under the plea structure); other counts carried standard-range restorative sanctions or short probationary terms.
- At sentencing Snyder (allocuted) asserted PTSD from military service, remorse, lack of prior criminal history, and rehabilitative potential; the Commonwealth recommended a standard-range sentence per the plea agreement.
- The trial court imposed consecutive terms: 240–480 months for third-degree murder, plus 1–24 months consecutive for abuse of a corpse, and concurrent probation on the remaining counts (aggregate 241–504 months), then denied reconsideration; Snyder appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion by imposing consecutive high-end standard-range sentences and failing to account for mitigating/rehabilitative factors | Snyder: sentence was excessive though within guidelines; court ignored mitigating evidence (PTSD, remorse, no prior record, treatment efforts) and failed to tailor sentence to rehabilitative needs | Trial court/Commonwealth: sentence was within the plea agreement and guideline range; court considered mitigation, rehabilitation, and purpose of punishment and explained reasons for confinement and length | Court affirmed: no abuse of discretion; trial court considered required factors, did not misapply law, and reasonably imposed consecutive standard-range sentences |
Key Cases Cited
- Commonwealth v. Griffin, 65 A.3d 932 (Pa. Super. 2013) (procedural framework for discretionary-sentencing review)
- Commonwealth v. Sierra, 752 A.2d 910 (Pa. Super. 2000) (discretionary sentencing not reviewable as of right)
- Commonwealth v. Evans, 901 A.2d 528 (Pa. Super. 2006) (four-part test for invoking appellate review of discretionary aspects of sentence)
- Commonwealth v. Moury, 992 A.2d 162 (Pa. Super. 2010) (preservation and appellate review standards for sentencing challenges)
- Commonwealth v. Caldwell, 117 A.3d 763 (Pa. Super. 2015) (requirement that court consider protection of public, gravity of offense, and rehabilitative needs; when consecutive guideline-range sentences may present a substantial question)
- Commonwealth v. Fullin, 892 A.2d 843 (Pa. Super. 2006) (sentencing factors the court must consider)
- Commonwealth v. Mastromarino, 2 A.3d 581 (Pa. Super. 2010) (concurrent vs. consecutive decisions ordinarily not a substantial question)
- Commonwealth v. Lamonda, 52 A.3d 365 (Pa. Super. 2012) (consecutive sentences present substantial question only in extreme circumstances)
- Commonwealth v. Dodge, 77 A.3d 1263 (Pa. Super. 2013) (guideline-range consecutive sentences can raise substantial question where application is clearly unreasonable)
- Commonwealth v. Raven, 97 A.3d 1244 (Pa. Super. 2014) (concurrent/consecutive challenge with claim trial court failed to consider rehabilitative needs can present substantial question)
- Commonwealth v. Seagraves, 103 A.3d 839 (Pa. Super. 2014) (standard of review for sentencing abuse of discretion)
- Commonwealth v. Shugars, 895 A.2d 1270 (Pa. Super. 2006) (abuse of discretion defined in sentencing context)