Commonwealth v. Bennett, 57 A.3d 1185

Appellee, a non-shooter, was convicted of first-degree murder, conspiracy, PIC, and robberies in a joint trial with Mayo; Mayo was the shooter.
Trial court instructed on first-, second-, third-degree murder and voluntary manslaughter, plus conspiracy and accomplice liability; initial instruction emphasized defendant’s potential guilt without specifying sole reliance on the shooter’s intent.
Post-trial, PCRA court granted relief on claims of ineffective assistance for failing to object to the jury charge under Huffman-based theory and related grounds; Superior Court affirmed.
This Court granted allowance to address whether Huffman governs the case post hoc and whether relief was appropriate given newer Pennsylvania precedent and differences from Huffman.
Majority reverses, holding Huffman is not controlling here; the jury charge, when read as a whole, conveyed that first-degree murder required the specific intent to kill by the defendant, and there was no harmless-error disparity necessitating a new trial.
The Court declines to extend relief based on Wyatt’s unrelated outcome, and remands for denial of PCRA relief; jurisdiction is relinquished.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Huffman governs here	Commonwealth argues Huffman is effectively overruled and should control.	Bennett argues post-Huffman cases contexte does not require reversal; charge adequate as read in full.	Huffman not controlling; charge adequate when read as a whole.
Whether the jury instruction violated due process by diminishing the burden for first-degree murder	Commonwealth contends the charge correctly instructed on accomplice/conspiracy liability with requisite intent.	Appellee contends the charge allowed conviction without specific-intent-to-kill by non-shooter.	No due-process violation; instruction supported by Bachert and post-Huffman case law.
Appropriate remedy for alleged error	Commonwealth requests modification to second-degree murder where appropriate.	Appellee seeks new trial; argues Wyatt’s relief warrants identical relief here.	Remand denied; court declines to modify to second-degree or grant new trial based on this record.

Commonwealth v. Huffman, 638 A.2d 961 (Pa. 1994) (instruction error when any co-defendant could be convicted without separate intent to kill)
Commonwealth v. Thompson, 674 A.2d 217 (Pa. 1996) (correct accomplice liability charge; not per se requiring Huffman pattern words)
Commonwealth v. Simpson, 754 A.2d 1264 (Pa. 2000) (upholds coherent instructions showing specific intent to kill required for first-degree murder)
Commonwealth v. Bachert, 453 A.2d 935 (Pa. 1982) (accomplice liability requires the accomplice’s state of mind; basis for Huffman)
Commonwealth v. Chester, 733 A.2d 1242 (Pa. 1999) (discussed Huffman timing and did not create new law; pre-Huffman guidance)
Commonwealth v. Daniels, 963 A.2d 409 (Pa. 2009) (assesses Huffman in light of later developments; informs post-Huffman expectations)
Commonwealth v. Wayne, 720 A.2d 463 (Pa. 1998) (concerning vicarious liability and intent in homicide cases)
Commonwealth v. Speight, 854 A.2d 450 (Pa. 2004) (alternative articulation of first-degree murder instructions and intent)