Com. v. Stahl, D., 1937 WDA 2014

David Stahl was convicted by a jury of first‑degree murder for the February 18, 2012 strangulation death of his wife, Rebecca Stahl, and sentenced to life imprisonment.
Evidence included autopsy findings of severe internal and external injuries consistent with manual strangulation and blunt force trauma, blood and DNA linking both parties to items in the house, and discovery of the victim’s body wrapped and concealed under shrubs.
Police found bloodstains in the house, a replaced basement wall and new drywall, and male clothing and the victim’s personal items in the basement freezer; Appellant gave inconsistent statements and later admitted killing Rebecca, claiming self‑defense.
Appellant challenged admission of 34 autopsy photographs and a jury instruction stating specific intent can form in any amount of time.
Post‑trial, the Commonwealth sought restitution of ~$76,869 (funeral costs, legal fees, administrative expenses); the trial court awarded $14,116.55 (funeral) but denied the remainder, including $46,535.10 in legal fees. Appeals by both parties and by Appellant from sentence were consolidated.

Issue	Commonwealth's / Plaintiff's Argument	Stahl's / Defendant's Argument	Held
Admissibility of autopsy photographs	Photos were relevant to show nature/extent of injuries and prove specific intent	Photographs were overly inflammatory and cumulative to Dr. Wecht’s testimony	Admitted. Court found photos had essential evidentiary value that outweighed prejudice; images helped prove ferocity and intent.
Jury instruction on specific intent timing	N/A (no Commonwealth challenge)	Instruction stating intent can form in any amount of time overstated the law and prejudiced defendant	Affirmed. Court held instruction was a correct statement: premeditation can form in a brief period (even seconds).
Restitution — funeral/burial expenses	Sought full restitution including funeral and other costs	Challenged scope/legality of restitution for certain items	Funeral expenses ($14,116.55) awarded. Court held funeral costs recoverable under §1106.
Restitution — legal fees and administrative expenses to estate/relative	Argued legal fees and family administrative costs are recoverable as losses to the victim’s estate	Argued such claims were speculative, not estate losses, and some claimed amounts were not paid	Denied. Court found Commonwealth failed to prove reasonableness or that the estate suffered actual loss; family members are not independent victims under §1106 per precedent.

Commonwealth v. Haney, 131 A.3d 24 (Pa. 2015) (autopsy photos admissible to show nature/extent of injuries and specific intent)
Commonwealth v. Woodard, 129 A.3d 480 (Pa. 2015) (autopsy images relevant to prove injury severity and intent)
Commonwealth v. Watkins, 108 A.3d 692 (Pa. 2014) (autopsy photos admissible; jury instructions and admonitions mitigate prejudice)
Commonwealth v. Lebarre, 961 A.2d 176 (Pa. Super. 2008) (funeral expenses recoverable as restitution to victim’s estate)
Commonwealth v. Langston, 904 A.2d 917 (Pa. Super. 2006) (§1106 restitution limited to the direct victim, not third‑party family members)
Commonwealth v. Jordan, 65 A.3d 318 (Pa. 2013) (explaining first‑degree murder requires malice and specific intent; premeditation can form quickly)