Commonwealth v. Baldwin
58 A.3d 754
Pa.2012Background
- Baldwin killed his roommate after altercation over a notice to vacate, then dismembered the body and buried remains in a shallow grave.
- The next day police found the remains and a note with Baldwin’s name; Baldwin admitted the homicide.
- Baldwin was tried on homicide and abuse of a corpse, raising an insanity defense.
- During the Commonwealth’s case, Baldwin indicated a desire to speak with the court; defense counsel explained waivers and procedures to him.
- After the defense rested, Baldwin’s counsel indicated he would not call Baldwin to testify; the court conducted a colloquy and Baldwin waived his right to testify.
- The next morning Baldwin reversed, seeking to testify, but the court denied reopening; the jury later found Baldwin guilty and sentenced him.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Peterson framework to reopen is constitutional for right to testify | Baldwin argues Peterson framework burdens his constitutional right | Commonwealth argues Peterson is a helpful framework within abuse-of-discretion review | Peterson framework adopted as guidance; no constitutional burden error |
| Whether the Superior Court properly applied Peterson factors to Baldwin’s request | Baldwin contends the record lacks content to assess value of testimony | Commonwealth contends factors applicable and record sufficient | Peterson factors properly applied; no abuse of discretion in denying reopening |
| Whether trial court abused its discretion by denying reopening after waiver | Baldwin sought to testify to corroborate insanity opinion | Court balanced, noting disruption and lack of excuse for late change | No abuse of discretion; denial upheld |
Key Cases Cited
- United States v. Peterson, 233 F.3d 101 (1st Cir. 2000) (guidance on whether to reopen for defendant’s testimony after waiver)
- United States v. Jones, 880 F.2d 55 (8th Cir. 1989) (reframing reopening decision; balance of interests)
- Jermyn, 516 Pa. 460, 533 A.2d 74 (Pa. 1987) (limits on right to testify; admissibility and procedure)
- Chambers, 546 Pa. 370, 685 A.2d 96 (Pa. 1996) (reopening to prevent miscarriage of justice; discretion standard)
- Tharp, 575 A.2d 557 (Pa. 1990) (discretion to reopen before final judgment)
- Commonwealth v. Baldwin, 32 A.3d 1259 (Pa. 2011) (per curiam; discusses Peterson framework in reopening)