Commonwealth v. Chamberlain
30 A.3d 381
| Pa. | 2011Background
- Two victims shot in their home; entry by breaking sliding door with a typewriter; blood evidence at scene but no weapon found.
- Appellant Chamberlain was convicted of two counts of first-degree murder, burglary, and possessing an instrument of crime; death sentence imposed.
- DNA testing of blood evidence was sought on remand after Supreme Court remanded for testing; trial court denied continuance.
- Evidence at trial centered on Kim Ulrich’s telephone-dyadic identification of “Terry” as the killer and corroborating circumstantial evidence.
- Blood evidence went missing after initial testing; on remand, the court found no bad faith and held the missing evidence did not entitle relief; DNA testing was not ultimately performed.
- Court affirmed death sentences after independent review of sufficiency and numerous post-trial challenges, including Brady, missing evidence, and prosecutorial arguments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Chamberlain challenging Ulrich’s identification | Commonwealth argues sufficiency supports guilt | Sufficiency established; guilt upheld. |
| Missing blood evidence and due process | Blood evidence was material/exculpatory and lost | No bad faith; not central; no relief | No due process violation; no relief. |
| Redial function evidence | Redial evidence could have been exculpatory | Destruction not federal due process violation; not central | No federal relief; no state relief due to waiver/centrality. |
| Prosecutorial misconduct in closing | Statements calling defendant a murderer prejudicial | Context showed fair deduction from evidence | No reversible error; arguments did not prejudice the outcome. |
| Vindictive prosecution claim | New charges after dismissals suggest vindictiveness | No new charges; grand jury presentment supported charging | No vindictive prosecution. |
Key Cases Cited
- Commonwealth v. King, 554 Pa. 331, 721 A.2d 763 (Pa. 1998) (independent sufficiency review in capital cases)
- Commonwealth v. Snyder, 963 A.2d 396 (Pa. 2009) (bad faith requirement for missing evidence (federal standard))
- Youngblood v. Arizona, 488 U.S. 51, 109 S. Ct. 333 (U.S. 1988) (missing evidence requires bad faith for due process)
- Illinois v. Fisher, 540 U.S. 545 (U.S. 2004) (potentially useful evidence – bad faith required)
- Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194 (U.S. 1963) (duty to disclose exculpatory evidence)
- Agurs v. United States, 427 U.S. 97, 96 S. Ct. 2392 (U.S. 1976) (duty to disclose exculpatory evidence even if not requested)
- Deans v. Commonwealth, 610 A.2d 32 (Pa. 1992) (centrality/state due process analysis (overruled for federal))
- Youngblood (see above), — (—) (as above)
- D’Amato v. Commonwealth, 526 A.2d 309 (Pa. 1987) (prosecutor's closing arguments; fair deduction standard)