Commonwealth v. Medina
92 A.3d 1210
| Pa. Super. Ct. | 2014Background
- In 1992 Jose Medina was convicted of first-degree murder, robbery, and PIC based primarily on testimony from two child witnesses, Michael and Hector Toro; no forensic link to Medina existed.
- Medina was sentenced to life without parole; direct appeals and initial PCRA proceedings were unsuccessful; a federal habeas court granted relief on ineffective-assistance grounds but the Third Circuit reversed.
- In 2006 Hector provided an affidavit recanting his trial testimony and alleged police coercion; Medina filed a second PCRA petition asserting after-discovered evidence and (alternatively) governmental interference.
- After multi-day evidentiary hearings the PCRA court found Hector’s recantation credible, Michael’s testimony unreliable/incompetent, concluded the petition met the timeliness exception, and granted a new trial. The Commonwealth appealed.
- The Superior Court (en banc) affirmed the PCRA court: it held the second PCRA petition was timely under the newly-discovered-fact exception, Hector’s recantation likely would produce a different verdict, and the PCRA court’s credibility findings were binding.
Issues
| Issue | Plaintiff's Argument (Medina) | Defendant's Argument (Commonwealth) | Held |
|---|---|---|---|
| Timeliness under PCRA §9545(b)(1)(ii) (newly-discovered facts) | Medina: Hector’s recantation and the detective’s coercion were unknown and first disclosed to Medina in Oct 2006; petition filed within 60 days. | Commonwealth: Medina lacked due diligence; he could have discovered or investigated Hector earlier given trial exposure. | Held: Petition timely — PCRA court’s findings that Medina learned recantation in Oct 2006 and exercised reasonable diligence were supported. |
| Whether recantation constituted after-discovered evidence warranting new trial (Pagan four-part test) | Medina: Hector’s recantation was not merely cumulative, directly contradicted trial testimony (including Michael’s), and would likely change verdict given weak circumstantial case. | Commonwealth: Recantation is the least reliable evidence, largely corroborative, and other circumstantial evidence supports conviction. | Held: Granted — PCRA court credited Hector’s recantation and found a strong likelihood of different verdict; appellate court found no abuse of discretion. |
| Competency/reliability of Michael Toro at PCRA hearing | Medina: Michael’s inconsistent statements and poor memory rendered him unreliable; PCRA court could exclude or discount his testimony. | Commonwealth: Michael was competent; PCRA court erred in deeming him incompetent or incredible. | Held: PCRA court’s credibility and competency determinations stand; Michael was found unreliable and his PCRA testimony discounted. |
| Recusal and procedural fairness | Medina: PCRA proceedings were fair; court acted within role as factfinder. | Commonwealth: Alleged bias, sua sponte rulings, and other procedural errors warranted recusal. | Held: Denied — court found Commonwealth’s recusal claims unsubstantiated. |
Key Cases Cited
- Commonwealth v. Edmiston, 65 A.3d 339 (Pa. 2013) (standard of review for PCRA appeals)
- Commonwealth v. Koehler, 36 A.3d 121 (Pa. 2012) (scope of review and deference to PCRA court findings)
- Commonwealth v. Spotz, 18 A.3d 244 (Pa. 2011) (credibility determinations by PCRA court are binding when supported)
- Commonwealth v. Bennett, 930 A.2d 1264 (Pa. 2007) (elements of newly-discovered-fact exception under §9545)
- Commonwealth v. Pagan, 950 A.2d 270 (Pa. 2008) (four-part test for after-discovered evidence warranting new trial)
- Commonwealth v. McCracken, 659 A.2d 541 (Pa. 1995) (recantation may qualify as after-discovered evidence when prior identification was unequivocal)