Com. v. Yeaples, B.
1172 WDA 2015
| Pa. Super. Ct. | Oct 19, 2016Background
- In October 2013 a 23‑month‑old child (Victim) was brought to the hospital with extensive external and internal injuries (multiple bruises, skull laceration, three rib fractures, liver hematoma, hemoperitoneum) requiring two blood transfusions; treating pediatrician diagnosed acute nonaccidental trauma within 24 hours.
- Defendant Bryant Yeaples lived in the household and was the child’s primary caretaker during the relevant period; Victim’s mother (Barden) worked outside the home and left with the child on the morning of October 26, 2013 to seek help.
- Yeaples gave multiple, inconsistent accounts to the mother and police about how injuries occurred (cigarette‑butt choking, bathtub/near‑drowning, slipping on a plate and falling on the child, being struck), and later apologized and admitted hitting the child during police interviews.
- Defense witnesses (household members) offered testimony that contradicted portions of the Commonwealth’s timeline and said they did not observe the injuries before the child left the home; defense argued other actors or accidents could explain some marks.
- A jury convicted Yeaples of aggravated assault (18 Pa.C.S. § 2702(a)(1)) and found the victim was under 13; Yeaples received 90 to 180 months’ imprisonment. He appealed raising sufficiency, weight, and evidentiary (prior bad acts and photos) claims; Superior Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to prove Yeaples inflicted injuries | Commonwealth: circumstantial proof — Yeaples was primary caregiver during injury window; medical testimony tied injuries to that period; inconsistent statements and consciousness‑of‑guilt evidence identify him | Yeaples: testimony (esp. Barden) conflicted with timing and appearance of injuries; medical timing + Barden’s observations create reasonable doubt as to who caused injuries | Conviction upheld — evidence (including circumstantial and statements) sufficient to prove identity and intent beyond reasonable doubt |
| Weight of the evidence | Commonwealth: evidence was credible and for the jury to weigh | Yeaples: verdict shocks justice because mother’s testimony and other evidence suggested injuries occurred after she left or were less severe at departure | Trial court did not abuse discretion; appellate court declines to reweigh evidence; weight claim denied |
| Admissibility of prior bad acts / prior incidents | Commonwealth: prior incidents and Yeaples’ statements probative of relationship to child, motive, consciousness of guilt, and provide context; admissible under Rule 404(b) purposes | Yeaples: prior incidents were irrelevant (did not cause hospital injuries) and unduly prejudicial | Trial court properly admitted them — probative value (motive, identity, consciousness of guilt, context) outweighed prejudice; no abuse of discretion |
| Admissibility of photographs of Victim’s injuries | Commonwealth: photos assist jury in assessing extent of visible injuries and extreme indifference; not merely cumulative of medical testimony | Yeaples: stipulation (or medical testimony) made photos unnecessary and inflammatory; unfair prejudice | Photos admissible — not overly inflammatory, probative for extreme indifference and not needlessly cumulative; trial court did not abuse discretion |
Key Cases Cited
- Commonwealth v. Melvin, 103 A.3d 1 (Pa. Super. 2014) (standard for sufficiency review and factfinder credibility deference)
- Commonwealth v. Brooks, 7 A.3d 852 (Pa. Super. 2010) (identity is an element of crime; circumstantial identification can suffice)
- Commonwealth v. Orr, 38 A.3d 868 (Pa. Super. 2011) (identification evidence need not be positive and certain)
- Commonwealth v. Widmer, 744 A.2d 745 (Pa. 2000) (standard for weight‑of‑the‑evidence review and appellate scope)
- Commonwealth v. Malloy, 856 A.2d 767 (Pa. 2004) (two‑part test for admissibility of inflammatory photographs)