Commonwealth v. Keaton
45 A.3d 1050
| Pa. | 2012Background
- Keaton was charged with rape and related offenses from multiple victims and later murder; charges were consolidated over defense objection.
- Keaton made statements incriminating himself after waiving Miranda rights in Hall's murder and in Michelle B.'s rape while in custody for Nadine S.'s rape.
- Guilt phase: jury convicted of first-degree murder, rape, and related offenses; penalty phase sought two aggravating factors and three mitigating theories from Keaton.
- PCRA court found trial counsel ineffective for failing to develop mitigating evidence; direct guilt claims were denied.
- Keaton's Atkins claim (mentally retarded) was remanded for merits finding; on remand the court held he is not mentally retarded.
- Commonwealth cross-appealed on penalty phase relief; a new penalty hearing was granted based on trial counsel's failure to investigate/present mitigating mental health evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Penalty-phase ineffectiveness for mitigating evidence | Keaton argues trial counsel failed to investigate/present mitigating mental health evidence | Commonwealth argues trial strategy or lack of available records justified conduct | Remanded: trial counsel's failure prejudiced penalty outcome; new penalty phase warranted |
| Right to counsel and suppression of statements | Keaton's statements should have been suppressed for violation of right to counsel | Statements were voluntary or not governed by attachment of counsel for the offenses | Remanded: factual finding needed on whether Keaton invoked his right to counsel; Shatzer considerations pending |
| Atkins claim viability | Keaton is mentally retarded under APA and AAMR definitions and cannot be executed | Keaton does not meet the mental retardation definitions | Keaton not mentally retarded; Atkins relief denied |
| Guilt-phase claims and appellate/waiver posture | PCRA/appellate strategy errors merit relief in guilt phase as previously raised | Many guilt-phase claims lack merit; layered/waived claims governed by precedents | Guilt-phase claims affirm denial of relief; focus remains on penalty-phase issues |
Key Cases Cited
- Commonwealth v. Williams, 950 A.2d 294 (Pa. 2008) (precludes extrapolating mitigation evidence without thorough investigation)
- Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (counsel's duty to investigate mitigating evidence)
- Bobby v. Van Hook, 130 S. Ct. 13 (U.S. 2009) (professional norms governing capital defense investigation)
- Commonwealth v. Rush, 838 A.2d 651 (Pa. 2003) (layered ineffectiveness claims and appellate strategy)
- Commonwealth v. Williams, 396 Pa. 1 (Pa. 1980) (general principles of trial counsel effectiveness (contextual reference))