Commonwealth v. Bryant
620 Pa. 218
| Pa. | 2013Background
- Appellant Bryant pled guilty to two counts of first-degree murder for January 19, 2008 killings of Chante Wright and Octavia Green, plus related charges.
- Commonwealth’s theory: Wright killed at Bey’s behest to prevent her testifying against Bey in Williams murder case.
- Penalty phase: jury found three aggravating circumstances for Wright and one for Green; single mitigating factor (8th) applied to both murders.
- Death sentence imposed on May 5, 2010; direct appeal under 42 Pa.C.S. § 9711(h)(1).
- Appellant challenges three penalty-phase issues: suppression of custodial statement, inflammatory photographs, and prosecutorial misconduct.
- Court affirmatively reviews sufficiency of evidence despite guilty pleas; finds evidence sufficient for first-degree murder elements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Suppression of statement admissibility | Bryant argues the February 8, 2008 statement was involuntary. | Suppression court erred by admitting coerced confession after lengthy custody. | Suppression denial affirmed; statement voluntary under totality of circumstances. |
| Admission of victim’s children photographs | Photographs were irrelevant and inflammatory, prejudicing the jury. | Photos clarifying victim impact were admissible to humanize harm. | No abuse; trial court did not err in admitting brief photos depicting children for victim impact purposes. |
| Prosecutorial misconduct during closing | Prosecutor biased and improper remarks denied Bryant a fair penalty phase. | Remarks were proper responses to defense arguments and contextualized. | No reversible error; mistrial not warranted; Assistant Prosecutor’s comments within deference of curative instructions. |
Key Cases Cited
- Commonwealth v. Perez, 577 Pa. 360, 845 A.2d 779 (Pa. 2004) (totality of the circumstances test for voluntariness)
- Commonwealth v. Hutchinson, 611 Pa. 280, 25 A.3d 277 (Pa. 2011) (prosecutorial misconduct standard; fair trial concerns)
- Commonwealth v. Eichinger, 591 Pa. 1, 915 A.2d 1122 (Pa. 2007) (evidence-admissibility and abuse of discretion standard)
- Commonwealth v. Marrero, 546 Pa. 596, 687 A.2d 1102 (Pa. 1996) (prosecutor may respond to defense arguments)
- Commonwealth v. Flor, 606 Pa. 384, 998 A.2d 606 (Pa. 2010) (victim-impact admissibility in capital sentencing)
- Commonwealth v. Wesley, 562 Pa. 7, 753 A.2d 204 (Pa. 2000) (curative instructions and mitigating error)