Commonwealth v. Morales, 625 Pa. 146

Death-sentence appeal following jury conviction for first-degree murder and burglary; aggravating factors outweighed mitigating factor at penalty phase, resulting in death sentence affirmed.
Controlled-drug buy from victim Simmons led to murder when defendant Morales used a gun and entered a locked residence to prevent testimony.
Codefendant Miles and others accompanied Morales; gloves and clothing described; victim was informant in drug case with impending testimony.
Physical evidence included palm print on back door matching Morales, gun recovered, and blood on shoes; officer Portner identified Morales from photo lineup.
Witness Portner identified Morales as the intruder; Miles/Nelson testified about events and Morales’ statements after the murder.
Court denied discovery motion to obtain witness Portner’s identity; trial admitted statements by the decedent under 804(b)(6) for wrongdoing and motive; juror 131 removed for uncertainty about death penalty verdict; affirmed death sentence after independent review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for murder and burglary	Appellant argues evidence is insufficient for guilt.	Commonwealth contends evidence proves all elements beyond reasonable doubt.	Sufficient evidence supports guilt beyond a reasonable doubt.
Weight of the evidence	Gaps and credibility issues warrant a new trial.	Jury credibility choices properly resolved conflicts.	No palpable abuse of discretion; weight of the evidence claim rejected.
Disclosure of witness Portner’s identity	Non-disclosure impaired cross-examination and fair trial rights.	Trial court properly balanced safety and defense needs; discretionary ruling.	No abuse; discretionary denial proper.
Admission of decedent's statements (forfeiture by wrongdoing)	Statements were improper hearsay and prejudicial.	Statements fall under 804(b)(6) and/or admissible for motive.	Waived; error not shown given other overwhelming evidence.
Dismissal of Juror No. 131	Removal violated defendant’s rights and violated Witherspoon/Witt/Uttecht protections.	Court acted within its discretion to replace a nonable juror.	No abuse of discretion; replacement proper.

Commonwealth v. Markman, 916 A.2d 586 (Pa. 2007) (sufficiency standard; circumstantial evidence permissible)
Commonwealth v. Tharp, 830 A.2d 519 (Pa. 2003) (credibility determinations; weight of evidence standard)
Commonwealth v. Houser, 18 A.3d 1128 (Pa. 2011) (weight-of-evidence standard; palpable abuse of discretion)
Commonwealth v. Diggs, 949 A.2d 873 (Pa. 2008) (weight-of-evidence context; credibility resolution)
Barber v. Page, 390 U.S. 719 (1968) (Confrontation and cross-examination considerations)