Commonwealth v. Martin, 101 A.3d 706

G.B., a 12-year-old girl, disappeared on June 13, 2006; her body was later found buried on a farm where Appellant worked and had recently spread manure.
Appellant, a farm worker, was present on the farm; ATV tied to the disappearance was found partially buried in a creek near the area where he operated.
Appellant was arrested without a warrant for tampering with evidence and hindering investigation; after Miranda warnings he provided a confession and later led police to burial sites of the victim and her belongings.
Autopsy evidence by Dr. Wecht showed death by manual strangulation and a vaginal injury with a high likelihood of penile penetration; these findings supported subsequent rape/sexual assault charges.
A consolidated trial convicted Appellant of first-degree murder and multiple sexual offenses; the sentencing jury imposed death after weighing aggravating and mitigating factors.
The suppression ruling upheld the warrantless arrest as supported by probable cause; Appellant challenged the suppression court’s findings and the admissibility of statements and the penalty-phase instructions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for rape/sexual assault	Appellant argues no proof of sexual intercourse beyond reasonable doubt.	Appellant contends the medical evidence and lack of eyewitnesses are inadequate.	Evidence sufficient to support convictions for rape/sexual assault/statutory sexual assault.
Penalty-phase reliance on unavailable sexual offenses	Penalties improperly considered rape/sexual offenses lacking sufficient proof.	Evidence supported aggravating factors based on convictions and surrounding circumstances.	Penalty-phase use of those offenses upheld; aggravators properly supported.
Was a sexually violent predator determination proper	SVP finding premised on unsupported rape/sexual offenses.	Trial properly considered the offenses and other evidence.	SVP finding affirmed; based on record evidence including prior convictions and treatment evidence.
Admission of rape/sexual offenses as aggravating factors	Trial erred by charging rape/sexual offenses as aggravators with insufficient proof.	The court properly charged aggravators supported by convictions and conduct.	Charging and consideration of these aggravators affirmed.
Suppression/arrest legality and compelled statements	Arrest lacked probable cause; statements were tainted by unlawful arrest and coercion.	Probable cause and voluntary waiver justified arrest and statements.	Warrantless arrest lawful; statements admissible; suppression court affirmed.

Commonwealth v. Flor, 606 Pa. 384 (Pa. 2010) (mandatory sufficiency review in capital cases)
Commonwealth v. Pruitt, 597 Pa. 307 (Pa. 2008) (sufficiency and mens rea standards for murder)
Commonwealth v. Johnson, 459 Pa. 141 (Pa. 1974) (intent to kill and strangulation evidence can support first-degree murder)
Commonwealth v. Meals, 590 Pa. 110 (Pa. 2006) (evidence sufficiency and weight of expert testimony)
Davis v. United States, 512 U.S. 452 (U.S. 1994) (clarification of invocation of right to counsel and custodial interrogation)
Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (protects right to counsel during custodial interrogation; police must cease questioning after invocation)
Whren v. United States, 517 U.S. 806 (U.S. 1996) (objective reasonableness governs Fourth Amendment stop analysis)
Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (totality of circumstances test for probable cause)
Commonwealth v. Thompson, 604 Pa. 198 (Pa. 2009) (probable cause and totality of circumstances standard in arrest)
Commonwealth v. Kelley, 569 Pa. 179 (Pa. 2002) (statutory definitions of sexual intercourse and penetration)
Commonwealth v. Thomas, 448 Pa. 42 (Pa. 1972) (circumstantial evidence can establish rape near time of death)