Commonwealth v. King
57 A.3d 607
| Pa. | 2012Background
- Co-defendant Bradley Martin used a prison visitation pass to escape; they killed Guy Goodman by binding, suffocating, and torturing him, then stole his checks and car; they used Goodman’s credit card and checks during flight.
- Appellant and Martin were tried together; Appellant testified and her tape-recorded confession was played for the jury; both were convicted of first-degree murder and related offenses.
- During penalty phase, the Commonwealth asserted two aggravators (felony murder and torture) and the jury sentenced both defendants to death with no mitigating factors found.
- Appellant filed a PCRA in 2000; after a five-day hearing, the PCRA court denied guilt-phase relief but granted a new penalty hearing based on trial counsel’s alleged ineffectiveness regarding mental-health mitigation.
- This appeal challenges guilt-phase relief, arguing trial counsel’s effectiveness issues (including inexperience, fee-cap conflicts, and failure to present psychiatric evidence) and related procedural points.
- The appellate court upheld guilt-phase conviction denial and affirmed that no structural error premised on counsel’s experience or fee arrangements warranted relief under Cronic/Mickens analyses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does trial counsel’s inexperience create per se prejudice under Cronic? | King argues structural error due to Weiss’s lack of capital-case experience. | King contends Weiss’s inexperience caused presumptive prejudice. | No per se structural prejudice; prejudice must be shown under Pierce/Strickland. |
| Was there a structural error due to a fee-cap conflict of interest under Cronic/Sullivan? | King argues fee ceiling created an actual conflict harming representation. | King relies on novel per se theory; conflict requires adverse effect, not automatic reversal. | Conflict theory rejected as per se; no demonstrated adverse effect requiring relief. |
| Did trial counsel fail to present diminished-capacity/duress mitigation mw evidence? | King contends psychiatric testimony could support duress or diminished capacity. | Weiss reasonably declined duress; diminished-capacity defense unavailable given record. | No ineffective-assistance relief; defenses not shown to be viable under existing jurisprudence. |
| Was Rule 801 prospective or retroactive to govern counsel competency at trial? | Rule 801 would have governed capital-counsel qualifications retroactively. | Rule 801 applies prospectively; not retroactive to Appellant’s trial. | Rule 801 not retroactive; did not compel finding of constitutional deprivation. |
| Were the asserted guilt-phase errors cumulatively prejudicial? | Combined errors undermined confidence in guilt-phase verdict. | Individual deficiencies insufficient; no cumulative prejudice. | Cumulative errors not sufficient to undermine confidence in guilt-phase verdict. |
Key Cases Cited
- McMann v. Richardson, 397 U.S. 759 (U.S. 1970) (establishes standard for ineffective assistance claims)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-part performance and prejudice standard)
- Cronic v. United States, 466 U.S. 648 (U.S. 1984) (presumed prejudice in certain pervasive representations)
- Holloway v. Arkansas, 435 U.S. 475 (U.S. 1978) (dual representation with conflicting interests can impair defense)
- Mickens v. Taylor, 535 U.S. 162 (U.S. 2002) (conflicts tied to personal/financial interests may affect representation but not always per se)