Com. v. Yeager, F.
Com. v. Yeager, F. No. 1266 EDA 2016
Pa. Super. Ct.Jun 13, 2017Background
- Yeager pled guilty to attempted rape; PCRA petition denied on April 4, 2016; Yeager challenges trial counsel for ineffective assistance related to corpus delicti objections and confession strategy.
- Victim was a realtor at Pulte Homes in Upper Macungie Township; Yeager entered the office and planned to lure her to a model home for rape, intending to act while she was alone.
- Yeager waited in the model home, manipulated lighting and curtains, and prepared a plan to attack; a male coworker interrupted, causing Yeager to abort.
- Police recovered Yeager’s truck and home, uncovering substantial evidence (notes, drawings, suicide notes, realty brochures, weaponry) connected to rape fantasies and planned attacks.
- Evidence included Yeager’s statements and notes supporting the intent and plan, with mental health issues and heavy alcohol use contributing to his behavior.
- Trial counsel concluded challenging the confession would likely fail and would jeopardize a plea deal; Yeager accepted a guilty plea with sentencing mitigation as the best path.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel was ineffective for not challenging corpus delicti. | Yeager; corpus delicti would bar the confession. | Yeager; no reasonable basis to admit confession. | No error; corpus delicti corroboration supported admission. |
| Whether corpus delicti rule applies to these statements. | Yes, confession should be excluded if corpus delicti not proven. | Corroborating evidence sufficed to satisfy corpus delicti. | Corpus delicti satisfied by corroborating evidence. |
| Whether the closely related crime exception applies to these statements. | Exception could preclude using statements. | Not applicable here. | Not applicable; statements admissible under corpus delicti framework. |
| Whether counsel’s course of action had a reasonable basis and whether but-for ineffectiveness changed outcome. | Strategy to plead guilty and mitigate. | Strategy driven by counsel’s experience; plea best interests. | Counsel had a reasonable basis; no reasonable probability of different outcome. |
Key Cases Cited
- Commonwealth v. Taylor, 831 A.2d 587 (Pa. 2003) (corpus delicti requires corroboration; independent evidence supports trustworthiness of statement)
- Commonwealth v. Spotz, 84 A.3d 294 (Pa. 2014) (ineffective assistance of counsel standard includes three-prong test)
- Commonwealth v. Washington, 927 A.2d 586 (Pa. 2007) (reasonableness of counsel's actions; not perfection but rational basis)
- Commonwealth v. Fowler, 670 A.2d 153 (Pa. Super. 1996) (trial counsel broad discretion in defense strategy)
- Commonwealth v. Ousley, 21 A.3d 1238 (Pa. Super. 2011) (presumed effective assistance; failure to prove prongs defeats claim)