Com. v. Watson, L.
Com. v. Watson, L. No. 3250 EDA 2015
| Pa. Super. Ct. | Aug 3, 2017Background
- Leon Watson, a youth football coach, was tried and convicted for multiple sexual offenses involving five juveniles and one mentally disabled adult, occurring between 2012–2013.
- Charges included IDSI, IDSI with a child, corruption of minors, unlawful contact with a minor, indecent assault, and related counts; consolidated for a single jury trial.
- Commonwealth presented testimony from all six victims and introduced testimony about Watson’s juvenile adjudication for sexual offenses (2005) via his brother’s testimony and Watson’s admission.
- Jury convicted Watson on all counts; the trial court imposed an aggregate sentence of 114 to 228 years’ imprisonment plus 35 years’ probation.
- On appeal Watson raised (1) competency-questioning of juvenile witnesses in front of the jury, (2) denial of severance/consolidation and admission of prior juvenile offenses, and (3) challenges to the discretionary aspects of sentencing.
- The Superior Court affirmed, finding (a) competency inquiries did not violate Washington given Hutchinson limits, (b) consolidation and admission of prior juvenile adjudication were within discretion under common-scheme/plan reasoning, and (c) sentencing discretion was not abused and sentencing considerations (PSI, mitigation) were considered.
Issues
| Issue | Commonwealth's Argument | Watson's Argument | Held |
|---|---|---|---|
| Competency questioning of juvenile witnesses in jury presence | Competency voir dire-like questions were proper; formal competency hearings were held outside jury presence and jury was instructed on credibility | Questions in front of the jury violated Pennsylvania’s per se Washington rule and required new trial | No error: competency hearings were held outside jury; limited questions in front of jury did not amount to Washington violation per Hutchinson and jury was instructed to judge credibility |
| Consolidation / motion to sever (juvenile victims + adult victim) | Joinder appropriate because crimes formed a common plan/scheme (similar victims, access via coaching role, overlapping time frame) and jury could separate evidence | Consolidation prejudiced Watson by portraying him as an uncontrollable predator; adult victim materially different (age, location, restraint) | No abuse of discretion: offenses sufficiently similar (signature/common plan), not confusing to jury, and defendant failed to show undue prejudice |
| Admission of juvenile adjudication and related testimony (prior bad acts) | Prior juvenile acts were admissible under common plan/scheme exception to Rule 404(b) given similarities and probative value; remoteness did not outweigh probative value | Prior juvenile acts were too remote and lacked the required signature-like similarity, so their admission impermissibly showed propensity | No abuse: prior juvenile conduct fit the common-scheme narrative, time gaps (with incarceration excluded) were not excessive, and probative value outweighed prejudice |
| Discretionary aspects of sentence (consecutive, length, and reasons on record) | Sentencing court considered PSI and relevant factors, reasonably imposed consecutive sentences given severity and victim count | Aggregate sentence excessive; court failed to state adequate reasons on the record and failed to account for mitigating factors (mild intellectual disability, history of abuse, rehabilitative needs) | No relief: consecutive long sentence lawful and not an extreme abuse; sentencing court reviewed PSI and considered mitigation and rehabilitation but reasonably concluded lengthy incarceration appropriate |
Key Cases Cited
- Commonwealth v. Washington, 772 A.2d 643 (Pa. 2001) (established per se rule requiring competency hearing outside jury when trial court rules on competence in jury presence)
- Commonwealth v. Hutchinson, 25 A.3d 277 (Pa. 2011) (clarified Washington: limited competency-like questioning may be permissible if court does not rule on competence in jury presence and jury is instructed)
- Commonwealth v. Delbridge, 855 A.2d 27 (Pa. 2004) (discusses competency standards for juvenile witnesses)
- Commonwealth v. Dowling, 883 A.2d 570 (Pa. 2005) (competency of juvenile witnesses is within trial court's discretion)
- Commonwealth v. Boyle, 733 A.2d 633 (Pa. Super. 1999) (framework for joinder/severance: admissibility, separability, prejudice)
- Commonwealth v. Tyson, 119 A.3d 353 (Pa. Super. 2015) (analyzing common plan/signature, remoteness, and probative value vs. prejudice)
- Commonwealth v. Newman, 598 A.2d 275 (Pa. Super. 1991) (on prejudice in joinder context—propensity vs. probative evidence)
- Commonwealth v. Hallock, 603 A.2d 612 (Pa. Super. 1992) (presumption sentencing court considered PSI and relevant mitigating information)
- Commonwealth v. Moury, 992 A.2d 162 (Pa. Super. 2010) (consecutive sentences generally left to sentencing court; extreme cases only create substantial question)