Commonwealth v. Koehler
36 A.3d 121
| Pa. | 2012Background
- Appellant Koehler convicted in 1996 of two counts of first-degree murder for Regina Clark and Austin Hopper.
- Evidence at trial included Curley’s testimony and Schrader’s testimony; Curley testified to coercion and bargaining by the Commonwealth.
- Curley later testified in a separate trial; the Commonwealth bound Curley’s cooperation to mitigation for his sentencing; Curley received a bench trial.
- PCRA petition filed September 2001 alleging ineffective assistance of trial and appellate counsel, Brady violations, and mitigation failures; evidentiary hearings held 2006–2007.
- PCRA court denied relief in 2009; affirmed on appeal; Pennsylvania Supreme Court reviewed standard Strickland analysis and upheld denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady disclosure of witness deals | Koehler asserts undisclosed agreements with Curley and Schrader | Commonwealth contends no undisclosed deals; Schrader’s agreement revoked prior to trial | Brady claims fail; no undisclosed impeachment evidence existed |
| Substantive due process from inconsistent theories | Inconsistent prosecutions between Koehler and Curley violated due process | Theories were harmonized; not a due process violation; trial strategy reasonable | Waived on direct appeal; no merit; no due process violation established |
| Mitigation evidence at penalty phase | Trial counsel failed to present extensive mitigation and expert testimony | Mitigation evidence available was limited; reweighing shows no prejudice | No reasonable probability of different outcome; no prejudice |
| Huffman/instruction and prejudice | Trial court violated Huffman by allowing a flawed specific-intent instruction | Daniels controls; viewed in entirety, correct instructions on intent were given | Not prejudicial under Daniels; no relief |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes standard for ineffective assistance of counsel)
- Commonwealth v. Colavita, 606 Pa. 1, 993 A.2d 874 (Pa. 2010) (three-part Strickland framework and reasonable basis in trial strategy)
- Commonwealth v. Lesko, 609 Pa. 128, 15 A.3d 345 (Pa. 2011) (trial strategy and prejudice assessment; remand framework used)
- Commonwealth v. Paddy, 15 A.3d 431 (Pa. 2011) (assessment of future dangerousness and Simmons-type claims)
- Commonwealth v. Daniels, 600 Pa. 1, 963 A.2d 409 (Pa. 2009) (Huffman-type charge evaluated in full jury instructions)
- Commonwealth v. Huffman, 586 Pa. 196, 638 A.2d 961 (Pa. 1994) (prohibition on relying solely on accomplice's state of mind for specific intent)