Com. v. Tyler, C.
257 WDA 2016
| Pa. Super. Ct. | Dec 2, 2016Background
- On October 4, 2014, a shooting at New Pennley Apartments killed Reginald Turner; Copeland Tyler was found at the scene with a gunshot wound and later admitted to shooting Turner.
- Crime-scene evidence included five .380 and three .45 shell casings; no firearm was recovered that night.
- Tyler gave statements to police (Miranda warnings were given at headquarters) claiming he feared for his life, but also said Turner "had to die." An Instagram video showed Tyler firing a .45 into the air.
- Tyler was charged with criminal homicide, carrying a firearm without a license, and possession-prohibited; convicted at a non-jury trial of voluntary manslaughter and the two weapons offenses.
- At sentencing the court imposed consecutive aggravated-range terms totaling 12½ to 29 years and ordered restitution; Tyler filed a post-sentence motion and appealed, arguing the sentence was manifestly excessive and the court failed to consider mitigating factors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the sentence was manifestly excessive/abused discretion | Commonwealth: sentence within statutory limits and supported by aggravating facts | Tyler: court focused only on seriousness, imposed aggravated-range sentence without adequate reasons or mitigation consideration | Affirmed: no manifest abuse; court considered PSR, testimony, age, prior gun convictions, Instagram video, and stated rehabilitative rationale |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings and custodial interrogation rule)
- Commonwealth v. Devers, 546 A.2d 12 (Pa. 1988) (presumption that sentencing judge considered presentence report and relevant mitigating information)
- Commonwealth v. Walls, 926 A.2d 957 (Pa. 2007) (deferential standard of review for discretionary sentencing)
- Commonwealth v. Hyland, 875 A.2d 1175 (Pa. Super. 2005) (aggravated-range sentence without consideration of mitigating factors raises substantial question)
- Commonwealth v. Duffy, 491 A.2d 230 (Pa. Super. 1985) (requirements for sentencing judge to state reasons for aggravated-range sentence)
- Commonwealth v. Crump, 995 A.2d 1280 (Pa. Super. 2010) (record must reflect consideration of crime facts and offender character)
- Commonwealth v. Tuladziecki, 522 A.2d 17 (Pa. 1987) (appellate relief only when sentence contravenes Sentencing Code or fundamental norms)