Commonwealth v. Haynes
125 A.3d 800
| Pa. Super. Ct. | 2015Background
- On Sept. 10, 2012, Roysce Haynes was arrested after admitting he choked his girlfriend, Atiya Perry, who died; autopsy ruled homicide by strangulation and showed Perry was ~7 weeks pregnant.
- Haynes was charged with third‑degree murder (adult victim) and third‑degree murder of an unborn child; jury convicted him of both on Apr. 30, 2014.
- Trial court sentenced Haynes July 1, 2014 to 20–40 years for third‑degree murder and 15–30 years consecutive for third‑degree murder of an unborn child (aggregate 35–70 years).
- The Commonwealth appealed, arguing 42 Pa.C.S. § 9715 mandated a life sentence because one murder conviction qualified as a prior "murder at any time." Haynes cross‑appealed, arguing his aggregate sentence was manifestly excessive and that the court failed to account for his mental health needs.
- The Superior Court reviewed statutory construction of § 9715 and the sentencing discretion record and affirmed: § 9715 does not include murder of an unborn child as a predicate, and the individual sentences fell within the standard guideline ranges.
Issues
| Issue | Commonwealth's Argument | Haynes' Argument | Held |
|---|---|---|---|
| Whether 42 Pa.C.S. § 9715 required imposition of life imprisonment because defendant had a separate murder conviction (murder of an unborn child) | § 9715's reference to "murder" unambiguously includes all degrees and therefore murder of an unborn child counts as a prior murder triggering mandatory life | N/A (defendant did not rely on § 9715) | Rejected: § 9715 does not list murder of an unborn child; Chapter 26 offenses are distinct from Chapter 25 murder, and omission of unborn‑child murder from § 9715 is intentional; life sentence not required |
| Whether Haynes' aggregate 35–70 year sentence is manifestly excessive or failed to account for mental health needs | N/A | Sentence exceeds aggravated guideline range and court failed to adequately consider mental health/rehabilitation | Rejected: Haynes' claims do not raise a substantial question as to consideration of mental health; each individual sentence was within the standard guideline range and the trial court reviewed the PSI and mental‑health report |
Key Cases Cited
- Commonwealth v. Morris, 958 A.2d 569 (Pa. Super. 2008) (discusses § 9715 application where defendant convicted of multiple murder counts)
- Commonwealth v. Luster, 71 A.3d 1029 (Pa. Super. 2013) (conviction for murder and murder of unborn child did not trigger § 9715 life sentence)
- Commonwealth v. Bullock, 913 A.2d 207 (Pa. 2006) (distinguishes sentencing for murders involving unborn child; separate sentencing outcomes)
- Commonwealth v. Booth, 766 A.2d 843 (Pa. 2001) (death of unborn child distinguished from general homicide predicates)
- Commonwealth v. Murray, 83 A.3d 137 (Pa. 2013) (noting statutory differences between first‑degree murder and first‑degree murder of an unborn child)
- Alleyne v. United States, 133 S. Ct. 2151 (U.S. 2013) (addresses limits on judge‑found facts increasing mandatory minimums; noted but not dispositive here)