Com. v. Warren, S.
Com. v. Warren, S. No. 1124 EDA 2016
| Pa. Super. Ct. | Jun 30, 2017Background
- On May 2, 2014, Shaheed Warren allegedly pulled a gun outside the Mark V Lounge and fired multiple shots, killing Dontae Brown and James Byrd and seriously wounding Ronald Edwards; ballistics showed all projectiles came from the same firearm.
- Witnesses placed Warren at the scene: Cinquetta Perrin (who knew Warren), eyewitness Jerry Carroll (saw the shooting up close), and hack driver Randolf Joyner (gave Warren a ride and described him to police).
- Surveillance footage corroborated flight from the scene; a shirt matching witness descriptions with Warren’s DNA was recovered at his home; recorded jail calls showed attempts to enlist others to contact/intimidate witnesses.
- At trial Perrin testified that Warren called her after the shooting and said, "I ain’t meant to kill the old head, but he was in the way." The Commonwealth had not disclosed that statement to defense counsel before it was elicited on direct examination.
- The trial court excluded the undisclosed statement on the record when defense objected and denied a mistrial; Warren was convicted after a bench trial and sentenced to two life terms plus 20–40 years.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Warren) | Held |
|---|---|---|---|
| Whether verdicts were against the weight of the evidence | Evidence (eyewitness IDs, ballistics, surveillance, DNA, witness-intimidation calls) support convictions | Eyewitness IDs were inconsistent and unreliable; verdict shocks sense of justice | Court affirmed: weight claim denied; credibility determinations for factfinder, no palpable abuse of discretion (verdict not shocking) |
| Whether failure to disclose a post-shooting admission warranted a mistrial | The trial court could exclude the undisclosed testimony and cure any prejudice | Failure to disclose Perrin’s testimony that Warren confessed was prejudicial and warranted mistrial | Court affirmed: trial court properly excluded the statement, denied mistrial; any error harmless given overwhelming evidence |
Key Cases Cited
- Commonwealth v. Devine, 26 A.3d 1139 (Pa. Super. 2011) (standard for appellate review of weight-of-the-evidence claims)
- Commonwealth v. Fortenbaugh, 69 A.3d 191 (Pa. 2013) (mistrial is remedy of last resort; prejudicial event must deprive defendant of fair trial)
- Commonwealth v. Smith, 97 A.3d 782 (Pa. Super. 2014) (presumption that trial court can ignore or exclude inadmissible/prejudicial evidence)
- Commonwealth v. Melvin, 103 A.3d 1 (Pa. Super. 2014) (harmless-error analysis when undisclosed statement is elicited)