Commonwealth v. Knox
50 A.3d 732
| Pa. Super. Ct. | 2012Background
- Appellant Devon Knox and his identical twin Jovon Knox were 17 at the time of the crimes; victim Jehru Donaldson (18) was shot in a parked car during an attempted robbery, causing a fatal crash.
- Two eyewitnesses identified Appellant as the shooter; another eye-witness testified the twins acted in concert in the robbery.
- Appellant was convicted of second-degree murder, attempted robbery of a motor vehicle, conspiracy-robbery, and possession of a firearm without a license; both twins received mandatory life imprisonment without parole for second-degree murder.
- Pennsylvania law required life-without-parole for juvenile murder under the then-existing statutory scheme; Miller v. Alabama (2012) later held such mandates unconstitutional for juveniles.
- The court vacated the judgment of sentence and remanded for resentencing, while affirming the convictions and addressing suppression and ineffective-assistance claims as to be further pursued; it also discussed the appropriate Miller-based considerations and anticipated briefing before resentencing.
- The appeal raised issues including weight of the evidence, the Eighth Amendment challenge to a life-without-parole sentence for a juvenile, suppression of a post-arrest statement, and whether post-sentence ineffective-assistance claims should be continued; one issue (ineffective assistance) was deemed waived for lack of developed argument.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight of the evidence | Knox argues the verdicts are against the weight given eyewitness non-shooter identification. | Commonwealth contends the evidence supports concerted action and liability. | Weight claim rejected; verdicts affirmed as not shockingly contrary to evidence. |
| Constitutionality of juvenile life without parole | Miller requires remand or different consideration; mandatory life without parole for juvenile homicide is unconstitutional. | Pennsylvania statutes mandate life without parole for juvenile second-degree murder irrespective of Miller. | Mandatory life without parole for juveniles violates Eighth Amendment and Pa. Const.; remanded for resentencing with individualized consideration. |
| Motion to suppress confession | Waiver of Miranda rights by juvenile without opportunity for adult consultation should render confession involuntary. | Totality of circumstances shows voluntary, knowing, and intelligent waiver. | Waiver deemed voluntary and intelligent; denial of suppression affirmed. |
| Post-sentence ineffective-assistance hearing | Hearing should continue to address trial counsel’s ineffectiveness. | Hearing was improperly developed; court lacked jurisdiction to continue. | Issue waived for lack of developed argument and authority; remanded or reconsideration not ordered. |
Key Cases Cited
- Commonwealth v. Young, 692 A.2d 1112 (Pa. Super. 1997) (weight-of-the-evidence standard guidance)
- Commonwealth v. Griffin, 684 A.2d 589 (Pa. Super. 1996) (scope of appellate review on weight of the evidence)
- Commonwealth v. Widmer, 560 Pa. 308 (Pa. 2000) (appellate review framework for weight claims)
- Commonwealth v. Cephas, 522 A.2d 63 (Pa. Super. 1987) ( Miranda waiver and voluntariness analysis framework)
- Commonwealth v. Nester, 709 A.2d 879 (Pa. 1998) (totality-of-the-circumstances test for Miranda waivers)
- Commonwealth v. T.B., 11 A.3d 500 (Pa. Super. 2010) (juvenile interrogations and presence of an interested adult as a factor)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (juvenile life-without-parole for non-homicide crimes unconstitutional; guiding principle for youth culpability)
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (mandatory life without parole for juveniles unconstitutional; requires individualized sentencing considerations)
- Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (death penalty barred for juveniles; diminished culpability of youth)
- Commonwealth v. Whitaker, 30 A.3d 1195 (Pa. Super. 2011) (application of Graham; later overruled by Miller)
- Commonwealth v. Carter, 855 A.2d 885 (Pa. Super. 2004) (earlier view on juvenile life sentences in PA PCRA context)
- Commonwealth v. Cottam, 616 A.2d 988 (Pa. Super. 1992) (Pennsylvania constitution coextensive with U.S. Constitution on cruel punishment)