Commonwealth v. Knox
50 A.3d 749
| Pa. Super. Ct. | 2012Background
- Knox and his identical twin brother Devon were 17 at the time of the crimes and were tried jointly; the Commonwealth proceeded on the theory that Devon was the shooter and Knox was his accomplice.
- On July 8, 2007, near 1:30 p.m., Knox and Devon approached the victim’s car and demanded him to exit, displaying a gun; when refused, a shot was fired and the victim crashed the car.
- Eyewitnesses Ah.C. and Aa.C. identified the Knox brothers in photo arrays as the two individuals who approached the car, with Ah.C. identifying Devon as the shooter.
- Knox and Devon fled the scene together, were later located, and Knox lied to police about his whereabouts; at trial, the brothers switched places, creating confusion about which twin committed the shooter act.
- The jury convicted Knox of second-degree murder, attempted robbery of a motor vehicle, conspiracy, and carrying a firearm without a license; he received a life sentence without parole for the murder charge via accomplice liability.
- This appeal challenged sufficiency of the evidence and the constitutionality of life without parole for a juvenile; the court remanded for resentencing after Miller v. Alabama (2012) held such mandatory sentences unconstitutional as applied to juveniles.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of conspiracy and accomplice liability evidence | Knox merely present; no aid or intent to aid Devon's crimes. | Presence and other circumstances show shared intent and conspiracy. | Evidence sufficient to support conspiracy and accomplice liability. |
| Sufficiency of firearm possession conviction under accomplice theory | Devon possessed the firearm; Knox cannot be guilty of possessing. | Accomplice liability makes Knox responsible for Devon’s possession. | Conviction for carrying a firearm without a license upheld under accomplice theory after overruling lack of direct possession. |
| Constitutionality of mandatory life without parole for a juvenile | Carter controls; life without parole for juvenile homicide is constitutional. | Graham/Miller require individualized sentencing due to youth; mandatory life without parole unconstitutional as applied. | Mandatory life without parole for a juvenile is unconstitutional as applied; Miller overrules Carter on this point; remand for resentencing. |
Key Cases Cited
- Commonwealth v. Brown, 23 A.3d 544 (Pa. Super. Ct. 2011) (standard for sufficiency of circumstantial evidence and jury credibility)
- Commonwealth v. McCall, 911 A.2d 992 (Pa. Super. Ct. 2006) (conspiracy proof may be inferred from circumstances)
- Commonwealth v. Rosetti, 469 A.2d 1123 (Pa. Super. Ct. 1983) (accomplice liability requires more than mere presence)
- Commonwealth v. Smith, 416 A.2d 494 (Pa. 1980) (accomplice liability for firearms offense among co-participants)
- Commonwealth v. Ortiz, 17 A.3d 417 (Pa. Super. Ct. 2011) (Graham applicability not expressly extending to PCRA timeliness; Ortiz footnote discusses Carter)
- Graham v. Florida, 560 U.S. 57 (U.S. 2010) (categorical ban on life without parole for juveniles in non-homicide offenses; evolving standards for juveniles)
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (mandatory life without parole unconstitutional for juveniles; requires individualized sentencing)
- Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (juvenile culpability and capacity for change reduce punishment severity)
- J.D.B. v. North Carolina, 131 S. Ct. 2394 (U.S. 2011) (juvenile characteristic considerations in law enforcement interactions)
- Woodson v. North Carolina, 428 U.S. 280 (U.S. 1976) (mandates individualized sentencing in death penalty contexts)
- Eddings v. Oklahoma, 455 U.S. 104 (U.S. 1982) (mitigating evidence relevant to sentencing juveniles)
- Commonwealth v. Carter, 855 A.2d 885 (Pa. Super. Ct. 2004) (prior panel holding that life without parole for juvenile homicide may be constitutional)
- Commonwealth v. Whitaker, 30 A.3d 1195 (Pa. Super. Ct. 2011) (post-Graham posture on juvenile life without parole)
- Graham v. Alabama (footnote in Ortiz context), 130 S. Ct. 2011 (U.S. 2010) (extends youth considerations to life-without-parole analysis)