Commonwealth v. Hairston
624 Pa. 143
| Pa. | 2014Background
- Hairston was convicted of two murders and sentenced to death in 2002; automatic review conducted due to death sentence.
- Evidence showed Hairston killed his wife and son on June 21, 2000, after a day of planning and then set the house on fire.
- Hairston faced related charges including rape, sexual assault, burglary, and attempted escape; later convicted on those charges in 2001.
- Initial post-sentence motions and direct appeal were not timely filed; appellate rights were reinstated nunc pro tunc after PCRA relief.
- The court conducted a sufficiency review and addressed numerous issues on appeal, upholding guilt and death sentences.
- During penalty phase, the jurors found two aggravating and two mitigating factors; reviewing court affirmed the sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Arson evidence admissibility | Hairston argues 404(b)(2) balancing was not performed and evidence prejudicial. | Hairston contends arson evidence was admitted improperly and prejudicially beyond its probative value. | Trial court did not abuse; arson evidence probative for intent and consciousness of guilt; balancing found satisfied. |
| Felony murder instruction | Prosecution argued arson as a felony; instruction requested to cover felony-murder theory. | No evidence showed murders occurred during arson; instruction unwarranted. | No error; evidence did not support a felony-murder instruction; proper trial ruling respected. |
| Prior assault/motive evidence | Evidence of May 21, 2000 assault and escape was probative of motive and sequence of events. | Evidence was unfairly prejudicial and should have been limited in scope. | Admissible for motive/intent; probative value outweighed prejudice; limitations and curative instructions applied. |
| Photographic evidence | Photos of the building exterior were prejudicial and unnecessary. | Photographs aided explanation of escape and corroborated other evidence. | Any error was harmless; photographs were non-inflammatory and substantially cumulative with other evidence. |
| Notice of aggravating circumstances | Commonwealth failed to provide timely notice under Rule 802; prejudice argued. | Constructive notice existed; amended notice timely; no prejudice shown. | No abuse; constructive notice and timely amendment complied with Edwards framework; no prejudicial error. |
Key Cases Cited
- Commonwealth v. Dengler, 586 Pa. 54 (Pa. 2005) (abuse-of-discretion standard for admission of evidence)
- Commonwealth v. Lark, 518 Pa. 290 (Pa. 1988) (limitations on prior-bad-acts evidence and necessity of probative value outweighing prejudice)
- Commonwealth v. Paddy, 569 Pa. 47 (Pa. 2002) (res gestae and admissibility of surrounding acts to tell the complete story)
- Commonwealth v. Williams, 557 Pa. 207 (Pa. 1999) (limits on evidence admissibility and necessity for trial context)
- Commonwealth v. Dillon, 592 Pa. 351 (Pa. 2007) (balancing probative value against prejudice; §403 considerations)
- Commonwealth v. Homeyer, 373 Pa. 150 (Pa. 1953) (admissibility of evidence to show motive, plan, or design)
- Commonwealth v. Giacobbe, 341 Pa. 187 (Pa. 1941) (admissibility of statements following police interrogation as consciousness of guilt)
- Commonwealth v. Baker, 531 Pa. 541 (Pa. 1992) (limiting instruction can cure potential prejudice from prior acts)
- Commonwealth v. Taylor, 583 Pa. 170 (Pa. 2005) (trial court control over victim impact testimony)
- Commonwealth v. Means, 565 Pa. 309 (Pa. 2001) (victim impact testimony controls and scope considerations)