Com. v. Stephenson, T.
Com. v. Stephenson, T. No. 1228 WDA 2016
| Pa. Super. Ct. | Jul 26, 2017Background
- On Nov. 19, 2014 Tracy Ann Stephenson was charged with homicide, aggravated assault, and carrying an unlicensed firearm after her mother, Barbara Elias, was found shot to death in Stephenson’s home.
- After waiving Miranda rights, Stephenson made spontaneous admissions outside the station and later confessed at the station, claiming her mother was poisoning her; police recovered a .32 revolver in her car.
- Stephenson gave notice of intent to pursue an insanity defense and was evaluated by defense and Commonwealth experts; both testified at sentencing about her mental illness and potential for rehabilitation.
- Stephenson moved to suppress her statements; the suppression motion was denied following hearings. She ultimately pled guilty to third-degree murder on Jan. 13, 2016.
- At sentencing the court considered a presentence report, testimony from Dr. Joseph Silverman (defense) and Dr. Wayne D’Agaro (Commonwealth), and evidence of Stephenson’s prison misconducts; the court imposed an 18–40 year standard-range sentence.
- Stephenson filed a post-sentence motion contending the court failed to account for her delusional beliefs and rehabilitative needs; the motion was denied and she appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court failed to incorporate Stephenson’s delusional beliefs into sentencing | Stephenson: court ignored/misapplied her delusional disorder and gave it no weight | Commonwealth/Court: court considered mental-health evidence and weighed it against public safety concerns | Court held it did consider her delusions; disagreement is only with the weight assigned, not a legal error — no abuse of discretion |
| Whether the court failed to consider Stephenson’s rehabilitative needs | Stephenson: court did not account for need for treatment and rehabilitation when sentencing | Commonwealth/Court: sentencing court had presentence report and heard conflicting expert opinions on rehabilitability | Court held rehabilitative needs were considered (presumed by presentence report); conflicting evidence supported the chosen standard-range sentence |
Key Cases Cited
- Commonwealth v. McLaine, 150 A.3d 70 (Pa. Super. 2016) (describing test to obtain review of discretionary sentencing claims)
- Commonwealth v. Walls, 926 A.2d 957 (Pa. 2007) (framework for appellate review of sentencing and when a sentence may be vacated)
- Commonwealth v. Devers, 546 A.2d 12 (Pa. 1988) (presumption that a sentencing court aware of relevant facts meaningfully weighed them)
- Commonwealth v. Ventura, 975 A.2d 1128 (Pa. Super. 2009) (relying on Devers presumption when court is informed by presentence report)
- Commonwealth v. Macias, 968 A.2d 773 (Pa. Super. 2009) (appellate court will not second-guess the weight assigned to mitigating factors)
- Commonwealth v. Downing, 990 A.2d 788 (Pa. Super. 2010) (stating that claim court failed to consider rehabilitative needs raises a substantial question)