Commonwealth v. Paddy
15 A.3d 431
| Pa. | 2011Background
- Appellant Donyell Paddy was convicted of first-degree murder and sentenced to death for Lashawn Whaley's 1993 killing, allegedly to prevent her testimony in prior Panati Playground murders.
- The Panati Playground murders occurred in 1991, with Whaley identifying Paddy as a perpetrator two years before her death.
- Appellant's first murder trial ended in a mistrial; a second trial in 1995 resulted in convictions for murder, conspiracy, witness retaliation, and crime instruments; death sentence followed a penalty phase.
- PCRA petitions were filed in 2002; counsel changes, pro se filings, and multiple petitions culminated in a Rule 907 dismissal without a hearing in 2005.
- Pennsylvania Supreme Court affirmed most PCRA dismissals, but remanded one penalty-phase claim alleging ineffective assistance of counsel in investigating and presenting mitigating life-history evidence, to be heard at an evidentiary hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel was ineffective in guilt phase | Paddy contends several trial-counsel failures; appellate counsel also ineffective for not raising them. | Commonwealth asserts claims are waived or meritless and previously litigated. | Guilt-phase claims largely rejected; many are waived or previously litigated. |
| Whether trial or appellate counsel erred regarding in camera testimony | Exclusion from an in camera hearing violated confrontation and ineffective assistance grounds. | No due process or confrontation error; counsel not ineffective given defendant's presence and cross-examination. | No reversible error; no ineffective assistance shown for absence from in camera hearing. |
| Whether Brady and other prosecutorial/forensic evidence issues warrant relief | Prosecution suppressed exculpatory material and misrepresented evidence affecting guilt/penalty. | Brady material not shown as material or suppressed; evidence consistent with trial record. | Brady claims rejected; no material suppression established. |
| Whether penalty-phase claims, including life-for-life and life-history mitigation, were properly handled | Trial counsel failed to investigate/present mitigating life-history evidence; appellate counsel ineffective for not pursuing. | Previous precedent does not mandate Simmons instruction; evidence and arguments were properly weighed; any issues were not prejudicial. | Remand for a limited evidentiary hearing on the penalty-phase mitigation-investigation issue; otherwise affirm PCRA dismissals. |
Key Cases Cited
- Commonwealth v. Grant, 572 Pa. 48, 813 A.2d 726 (2002) (direct-appeal counsel matters and Grant-era waivers)
- Commonwealth v. Pierce, 515 Pa. 153, 527 A.2d 973 (1987) (three-prong standard for ineffective assistance)
- Sochor v. Florida, 504 U.S. 527 (1992) (deadlines for harmless error analysis in capital cases)
- Commonwealth v. Morales, 508 Pa. 51, 494 A.2d 367 (1985) ("conviction" for aggravating factor context)
- Harrington v. Richter, 131 S. Ct. 770 (2011) (Strickland framework and deferential review guidance)