Commonwealth v. Horne
89 A.3d 277
Pa. Super. Ct.2014Background
- Horne was charged with a string of York County bank robberies in April–May 2009.
- Extradition under the Interstate Agreement on Detainers (IAD) encountered paperwork issues, delaying transfer and trial.
- Horne was incarcerated in Maryland and then Franklin County, PA, delaying availability for York County proceedings.
- Eventually, following Franklin County resolution, Horne was transferred to York County custody on December 23, 2010.
- Horne arrived in York County and trials across four dockets began in 2012, resulting in multiple guilty verdicts and an aggregate sentence of 16 to 45 years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| IAD compliance and 120-day timing | Horne argues IAD time was violated by improper calculation. | Horne contends York County did not exercise due diligence delaying custody. | No IAD violation; due diligence shown and timing lawful. |
| Rule 600 computation | Rule 600 clock should include all Commonwealth delays and exclude defensible periods. | Mechanical run date not expired; rulings should dismiss. | No Rule 600 violation; calculations within limits. |
| Admission of Bishop and Francis testimony | Testimony was unfairly prejudicial to Horne. | Testimony appropriate and admissible under evidentiary standards. | Court did not abuse discretion; testimony admitted. |
| Weight of the evidence | Jury’s verdict against the weight of the evidence due to inconsistencies. | Jury resolution within proper discretion; no weight-of-evidence error. | Verdict not against the weight of the evidence. |
Key Cases Cited
- Commonwealth v. Williams, 896 A.2d 523 (Pa. 2006) (IAD due diligence and transfer procedures)
- Commonwealth v. Merlo, 364 A.2d 391 (Pa. Super. 1976) (IAD detainer process and purpose)
- Commonwealth v. Woods, 663 A.2d 803 (Pa. Super. 1995) (due diligence standard for unavailable defendant)
- Commonwealth v. DeMarco, 481 A.2d 632 (Pa. Super. 1984) (extradition delay and IAD timelines)
- Commonwealth v. Boczkowski, 846 A.2d 75 (Pa. 2004) (appeals tolling and timely rulings in Rule 600 context)
- Commonwealth v. Ramos, 936 A.2d 1097 (Pa. Super. 2007) (Rule 600 considerations and speedy-trial balancing)
- Cuyler v. Adams, 449 U.S. 433 (U.S. 1981) (IAD principles and cross-jurisdictional detainers)