Commonwealth v. Landis
48 A.3d 432
| Pa. Super. Ct. | 2012Background
- Commonwealth appeals two pre-trial orders in Berks County related to the murder of Appellee Landis's wife and an ensuing police standoff.
- Landis was charged with murder and related offenses; after a lengthy standoff, the court severed the cases and granted a writ of habeas corpus on the assault of a law enforcement officer count.
- Commonwealth sought to introduce during the murder trial evidence that Landis shot at a detective, arguing it showed firearm familiarity and consciousness of guilt.
- The trial court denied the evidentiary motion but previously granted severance and habeas relief on the officer-assault charge.
- The en banc court held that the Commonwealth established a prima facie case for assault of a law enforcement officer and reversed the habeas writ on that count, remanding for further proceedings.
- The court also held that the probative value of the shooting-at-a-officer evidence could be admitted in the murder trial, reversing the trial court’s limiting ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Commonwealth established a prima facie case under § 2702.1 for assault of a law enforcement officer | Landis contends no prima facie case existed. | Commonwealth argues prima facie evidence from discharge of firearm and officer status suffices. | Yes; prima facie established; writ reversed and case remanded |
| Whether the evidence Landis shot at an officer is admissible in the murder trial to show familiarity with firearms and consciousness of guilt | Evidence is premature and improper without complete record. | Evidence tends to prove knowledge and intent; admissible with proper record. | Yes; reversed denial of motion in limine; admissibility appropriate upon record |
Key Cases Cited
- Commonwealth v. Winger, 957 A.2d 325 (Pa. Super. 2008) (prima facie standard for habeas corpus review)
- Commonwealth v. Patrick, 933 A.2d 1043 (Pa. Super. 2007) (elements of a prima facie case; binding over standard)
- Commonwealth v. Alford, 880 A.2d 666 (Pa. Super. 2005) (intent may be inferred from conduct; totality of evidence approach)
- Commonwealth v. Rosado, 684 A.2d 605 (Pa. Super. 1996) (reasoning on intended consequences in attempt crimes)
- Commonwealth v. Hall, 830 A.2d 537 (Pa. 2003) (pointing a gun toward a person as indicia of intent)
- Commonwealth v. Mohammed, 2012 WL 987799 (Pa. filed 2012) (statutory interpretation of 2702.1 language)