Commonwealth v. Johnson
42 A.3d 1017
| Pa. | 2012Background
- Two-year-old victim suffered extensive injuries and died after sustained torture by her mother's boyfriend, the appellant, over about 45–60 minutes.
- Victim exhibited numerous fresh and old injuries; pathologist found approximately 220 external injuries and extensive internal trauma leading to death.
- Appellant admitted to beating victim with a belt and described disciplining her prior to the fatal injuries.
- Mother testified inconsistencies existed regarding prior injuries; she pled guilty to third-degree murder in exchange for testimony.
- Trial resulted in first-degree murder conviction; two aggravating factors (torture and victim under 12) and one mitigating factor (no significant prior history) supported a death sentence.
- This direct appeal nunc pro tunc challenges multiple evidentiary and procedural issues before affirming the death sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for first-degree murder | Johnson lacked specific intent to kill | State showed intent via extensive injuries and deliberate beating | Sufficiency established; deliberate killing found |
| Admissibility of prior bad acts evidence | Older injuries showed pattern of abuse to prove malice | Probative value outweighed prejudice | Not an abuse of discretion; admissible to show relationship and malice |
| Admissibility of statements to Kohler and Sanders | Statements obtained in custody without Miranda should be suppressed | Not in custody; statements voluntary and admissible | Statements admissible; no Miranda violation; not custodian interdict |
| Validity of search warrants | Warrants lacked probable cause and specificity | Affidavits supported probable cause; warrants adequately described items | Probable cause and particularity satisfied; warrants upheld |
| Photographs of victim at guilt/penalty phases | Photos inflamed jurors; cumulative to testimony | Photographs essential to convey extent of injuries and pain | Photographs properly admitted; probative value outweighs inflammatory risk |
Key Cases Cited
- Commonwealth v. Dick, 602 Pa. 180, 978 A.2d 956 (2009) (obligation to review record for support of murder conviction and aggravating factors)
- Commonwealth v. Sherwood, 603 Pa. 92, 982 A.2d 483 (2009) (specific intent may be inferred from knowingly applying deadly force)
- Commonwealth v. Powell, 598 Pa. 224, 956 A.2d 406 (2008) (intent/malice; extensive injuries support intent to kill)
- Commonwealth v. Kennedy, 598 Pa. 621, 959 A.2d 916 (2008) (premeditation and specific intent framework for first-degree murder)
- Commonwealth v. Montalvo, 604 Pa. 386, 986 A.2d 84 (2009) (test for torture aggravator; duration and nature of injuries)