Commonwealth v. Bedford
50 A.3d 707
| Pa. Super. Ct. | 2012Background
- Bedford was convicted by jury of first-degree murder and PIC in Philadelphia County after a trial.
- Victim Sam Brown and Bedford had a dispute over $900 and broken car windows; confrontation occurred at Frances Quitman's home on May 28, 2006.
- Bedford allegedly shot Victim three times at close range; Victim died about an hour later at the hospital.
- Bedford fled Philadelphia, was captured in York under an assumed name (Karl W. Golden) after extensive search.
- Trial included Bedford's self-defense claim and a rebuttal witness (Sgt. Sean Butts) who testified to Victim's peaceful nature; issues about the admissibility of that character evidence.
- Appellant appealed raising sufficiency, mistrial for hearsay, admissibility of character evidence, and prosecutorial misconduct; en banc review followed, and the judgment was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to prove first-degree murder | Bedford | Bedford contends no specific intent to kill | Evidence supported specific intent to kill |
| Mistrial based on hearsay testimony | Bedford | Hearsay prejudiced trial | No abuse of discretion; no mistrial required |
| Admissibility of Sgt. Butts' character testimony | Bedford | Character evidence improperly admitted | Waived for lack of preservation; not reversible error |
| Prosecutorial misconduct during trial and closing | Bedford | Misconduct affected fairness of trial | No reversible prejudice; not entitled to new trial |
Key Cases Cited
- Commonwealth v. DeJesus, 860 A.2d 102 (Pa. 2004) (specific intent may be inferred from use of deadly weapon on vital area)
- Commonwealth v. Torres, 766 A.2d 342 (Pa. 2001) (sufficiency standard; review of evidence in light most favorable to verdict)
- Commonwealth v. Flamer, 848 A.2d 951 (Pa. Super. 2004) (standard against weighing evidence on appeal)
- Commonwealth v. Johnson, 838 A.2d 663 (Pa. 2003) (reputation vs. opinion evidence under Rule 405; preservation)
- Commonwealth v. Mollett, 5 A.3d 291 (Pa. Super. 2010) (jury may follow court’s instruction regarding evidence)
- Commonwealth v. Cousar, 928 A.2d 1025 (Pa. 2007) (preservation of objections to admission of evidence)