Commonwealth v. Padilla, 622 Pa. 449

Triple murder outside UVA club; appellant Miguel Padilla, an illegal Mexican national, was convicted of three counts of first-degree murder and sentenced to death; trial featured contested diminished-capacity defense based on alcohol/marijuana use.
Post-arrest, counsel conflicts and consular involvements arose; Mexico sought involvement and appointed counsel, but PA public defender ultimately represented Padilla.
VN: trial court interference with consular relations; pro se/Mexican-consulate motions were filed; court imposed procedural barriers to consular input.
Evidence showed deliberate, near-close-range shootings with multiple gunshots to three victims, and forensic links tied to a weapon tied to a Shumaker vehicle; transferred-intent doctrine applied for the bystander Heiss.
Penalty-phase evidence included three aggravators (felony in the course of a firearm possession, grave risk of death, and prior murder) and three mitigators; defense challenged validity of the 9711(d)(6) aggravator due to a mischaracterized firearm offense; court affirmed death verdicts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Conflict of interest during representation	Padilla—Speice had conflict by initial denial of counsel	Speice’s initial denial caused adverse effect	No conflict; denial did not prejudice
Delay in appointing counsel and Sixth Amendment impact	Delay violated Rule 122 and impaired defense	Delay did not prejudice; no Sixth Amendment violation	No reversible error; trial proper
Vienna Convention Article 36 violations	Mexico’s consular input was improperly restricted	Vienna rights either non-enforceable or properly limited by state rules	No Article 36 remedy warranted; claims meritless
Jury instruction on diminished capacity	Court erred by not recognizing diminished capacity evidence	Evidence did not support full diminished-capacity instruction	Instructions proper; no error
Aggravating factor 9711(d)(6) and stipulation	Stipulation to felony-based aggravator valid; notice sufficient	Aggravator based on a misdemeanor and was arbitrary; waiver and Chambers effects apply	Waived/deferral to collateral review; affirmed death sentence

Commonwealth v. Briggs, 608 Pa. 480, 12 A.3d 291 (Pa. 2011) (sufficiency review in capital cases; death penalty standards)
Commonwealth v. Houser, 610 Pa. 264, 18 A.3d 1128 (Pa. 2011) (elements of first-degree murder; malice and specific intent)
Commonwealth v. Williams, 589 Pa. 61, 650 A.2d 420 (Pa. 1994) (arbitrary-factor considerations in penalty phase; Williams framework)
Rothgery v. Gillespie County, 554 U.S. 191, 128 S. Ct. 2578 (U.S. 2008) (Sixth Amendment attachment; timing of counsel)
Sanchez-Llamas v. Oregon, 548 U.S. 331, 126 S. Ct. 2669 (U.S. 2006) (Vienna Convention Article 36 remedies and state-law implementation)
Commonwealth v. Boczkowski, 577 Pa. 421, 846 A.2d 75 (Pa. 2004) (deferral to PCRA for waivable, trial-counsel issues; arbitrariness analysis after waiver)
Commonwealth v. Chambers, 602 Pa. 224, 980 A.2d 35 (Pa. 2009) (waived penalty-phase claims deferred to collateral review; Chambers rule)
Gouveia v. United States, 467 U.S. 180, 104 S. Ct. 2292 (U.S. 1984) (pretrial critical stages and right to counsel)
Cronic v. United States, 466 U.S. 648, 104 S. Ct. 2039 (U.S. 1984) (pretrial deprivation of counsel presumed prejudicial)
Sanchez-Llamas (duplicate for emphasis), 348 U.S. cites repeated above (2006) (see above)