Commonwealth v. Haney, P., Aplt.
131 A.3d 24
| Pa. | 2015Background
- Appellant Patrick Ray Haney was convicted by jury of first-degree murder and endangering the welfare of a child in a capital case.
- Trenton Lewis St. Clair, age four, died from peritonitis due to a closed abdominal injury from battery; medical experts testified abuse, not a fall, caused death.
- Forsythe, Trenton’s mother, testified to sustained abuse by Appellant and observed bruising prior to death.
- Dr. Schmidt (forensic pathologist) and Dr. Larabee (emergency physician) opined the injuries were consistent with abuse and not with a fall; death ruled homicide.
- The Commonwealth presented photographs of Trenton’s body and multiple witnesses linking Appellant to abuse; the jury imposed a death sentence after aggravating factors of torture and victim under age twelve were found.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for first-degree murder | Haney argues no proof of specific intent to kill | Commonwealth proved malice and intent via pattern of abuse | Sufficiency established; evidence supports intent and malice beyond reasonable doubt. |
| Admission of photographs during deliberations | Photographs were inflammatory and cumulative | Photographs were probative of injuries and mens rea | Photographs properly admitted and allowed for jury view during deliberations; no abuse of discretion. |
| Aggravating torture factor should be jury-determined | There was no evidence of torture proof to support aggravator | Course of conduct showed intentional torture over time | Tortu re aggravator upheld; sufficient evidence to support jury’s finding. |
| Pretrial motions to dismiss charges | Pretrial rulings insufficient to sustain charges | Trial proceeded on valid charges with sufficient evidence | moot given conviction on first-degree murder; pretrial rulings affirmed by later judgment. |
| Whether death sentence lacks basis due to mitigating factors | No mitigating factors established | Potential mitigators not found credible or sufficient | Death sentence affirmed; no mitigating factors found. |
Key Cases Cited
- Commonwealth v. Powell, 598 Pa. 224, 956 A.2d 406 (Pa. 2008) (sufficiency of evidence for first-degree murder based on pattern of abuse)
- Commonwealth v. Johnson, 615 Pa. 354, 42 A.3d 1017 (Pa. 2012) (specific intent to kill proven circumstantially)
- Commonwealth v. Chambers, 602 Pa. 224, 980 A.2d 35 (Pa. 2009) (final blow not required where abuse supports conviction)
- Commonwealth v. Lee, 541 Pa. 260, 662 A.2d 645 (Pa. 1995) (mootness of pretrial issues when conviction sustained)
- Commonwealth v. Karenbauer, 552 Pa. 420, 715 A.2d 1086 (Pa. 1998) (photographs admissible to show injuries and intent to kill)
- Commonwealth v. Woodard, 634 Pa. 162, 129 A.3d 480 (Pa. 2015) (photographs of autopsy images admissible to show extent of injuries and mens rea)
- Commonwealth v. Tharp, 574 Pa. 202, 830 A.2d 519 (Pa. 2003) (two-step test for admissibility of homicide photographs)
- Commonwealth v. Rucci, 543 Pa. 261, 670 A.2d 1129 (Pa. 1996) (judicial discretion over viewing exhibits during deliberations)