Commonwealth v. Knight, M., Aplt.
156 A.3d 239
| Pa. | 2016Background
- Defendant pleaded guilty to first- and second-degree murder, kidnapping, and related conspiracies for the torture and murder of an intellectually disabled woman; jury later sentenced him to death after a penalty hearing.
- At penalty phase the Commonwealth relied heavily on cooperating co‑defendant Amber Meidinger’s testimony; evidence established prolonged torture, rape, binding, forced ingestion of bodily waste and chemicals, stabbing, slashing, and choking.
- Jury found two statutory aggravators: killing during perpetration of a felony and killing by means of torture; jury also found the (e)(8) catch‑all mitigator (mental health issues) and concluded aggravators outweighed mitigators.
- Defense argued four statutory mitigators including (e)(1) no significant prior criminal history; Detective Vernail testified defendant had no misdemeanor or felony convictions. Prosecutor declined to stipulate but conceded in closing that defendant had no prior convictions and urged the jury to give that little weight.
- Jury did not find the (e)(1) mitigator; the Supreme Court of Pennsylvania vacated the death sentence and remanded for a new penalty hearing because the (e)(1) mitigator was undisputed and thus the jury was required to find it.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient to support first‑degree murder conviction | Commonwealth: facts and plea show malice and specific intent | N/A (defendant pled guilty) | Court: evidence amply supported first‑degree murder; conviction not disturbed |
| Whether jury was required to find §9711(e)(1) (no significant prior convictions) when absence of convictions was undisputed | Knight: (e)(1) was established as a matter of law because no felony/misdemeanor convictions were proven and prosecutor conceded the fact; Rizzuto requires jury finding | Commonwealth: jury has discretion to find mitigators and may reject mitigation even if uncontradicted; Rizzuto limited to stipulations | Held: Vacated death sentence and remanded for new penalty hearing — where absence of prior convictions is indisputable, jury must be directed to find (e)(1) and include it in weighing (Rizzuto controlling) |
| Whether disparate plea deal for co‑defendant (Meidinger) rendered death sentence arbitrary or unconstitutional | Knight: unequal treatment; he cooperated/pleaded guilty and was denied life bargain while Meidinger got 40–80 years | Commonwealth: differences in culpability and remorse, and prosecutorial discretion; sentences of co‑defendants not ordinarily relevant | Held: Claim rejected — individualized sentencing and prosecutorial discretion permissible; no automatic constitutional bar to seeking death based on co‑defendant pleas |
| Admissibility and scope of penalty‑phase rebuttal and photographic evidence (raised as guidance for remand) | Knight: inadequate notice on videotape, introduction of unsustained prison infractions, and overly prejudicial/gruesome photos | Commonwealth: evidence relevant to rebut character and to prove torture aggravator; probative value outweighed prejudice | Held: Court raised concerns and advised greater circumspection on remand (narrow photos, limit prison reports, follow trial‑court moderation measures) |
Key Cases Cited
- Commonwealth v. Rizzuto, 777 A.2d 1069 (Pa. 2001) (where a mitigating circumstance is undisputed or stipulated, the jury must find it and consider it in weighing)
- Commonwealth v. Zettlemoyer, 454 A.2d 937 (Pa. 1982) (appellate sufficiency review in capital cases)
- Commonwealth v. Boczkowski, 846 A.2d 75 (Pa. 2004) (vacating death sentence where arbitrary factors affected aggravator findings)
- Commonwealth v. Ballard, 80 A.3d 380 (Pa. 2013) (guidance on limiting and formatting gruesome photographic evidence)
- Commonwealth v. Walter, 966 A.2d 560 (Pa. 2009) (jury has discretion to reject mitigating evidence absent stipulation)
- Commonwealth v. Reyes, 963 A.2d 436 (Pa. 2009) (scope of appellate review of death sentences and role of factfinder in weighing mitigators/aggravators)
- Commonwealth v. Haag, 562 A.2d 289 (Pa. 1989) (sentences of co‑defendants not dispositive; sentencing is individualized)
- Commonwealth v. Copenhefer, 587 A.2d 1353 (Pa. 1991) (discussed in Rizzuto; dissent argued undisputed absence of prior record must be found as mitigator)
- Commonwealth v. Diamond, 83 A.3d 119 (Pa. 2013) (reiterating jury’s discretion to find mitigators such as subjective impairments)
- Commonwealth v. Eichinger, 915 A.2d 1122 (Pa. 2007) (autopsy photographs relevant at penalty phase to show nature of acts)
- Commonwealth v. Maisonet, 31 A.3d 689 (Pa. 2011) (elements of first‑degree murder)