Commonwealth v. Haskins
60 A.3d 538
| Pa. Super. Ct. | 2012Background
- King and Haskins were convicted of first-degree murder and conspiracy; each sentenced to life for murder and 20–40 years for conspiracy.
- Defense witness Alston testified King and Haskins did not murder the victim; Cannon was the shooter.
- At trial, the Commonwealth depicted Alston as fabricating the claim after learning Cannon implicated him in other murders.
- Alston wrote a pretrial letter blaming Cannon and exculpatory details; the letter was seized before trial but not disclosed to defense.
- PCRA petitions were filed; the court found a Brady violation and granted new trials, prompting Commonwealth appeal.
- On appeal, court held the Brady letter was not material; the verdict would not have differed, reversing the new-trial order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there a Brady violation due to nondisclosure? | King/Haskins: yes, as acknowledged by the Commonwealth. | King/Haskins: no, diligence and nonexclusive control negate disclosure duty. | Brady violation acknowledged; however, not material to outcome. |
| Was Alston's letter material to the verdict under Brady? | King/Haskins: letter would rehabilitate credibility and probable acquittal. | King/Haskins: letter not material; overwhelming evidence against acquittal. | Letter not material; new trial improper. |
Key Cases Cited
- Commonwealth v. Dennis, 17 A.3d 297 (Pa. 2011) ( Brady standard for suppression, favorable evidence, materiality)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (materiality requires reasonable probability of different outcome)
- Commonwealth v. Paddy, 15 A.3d 431 (Pa. 2011) (burden on defendant to prove withholding by prosecution)
- Commonwealth v. Tedford, 960 A.2d 1 (Pa. 2008) (non-governmental source consideration in Brady analysis)
- Commonwealth v. Copenhefer, 719 A.2d 242 (Pa. 1998) (Brady injury requires undermining truth-determining process)
- Boss v. Pierce, 263 F.3d 734 (7th Cir. 2001) (limits diligence to information within witness’s role; mind-reading rejected)
- Commonwealth v. McGill, 832 A.2d 1014 (Pa. 2003) (materiality not shown by mere possibility of benefit)
- Commonwealth v. Green, 640 A.2d 1242 (Pa. 1994) (fair trial standard in assessing materiality)