Commonwealth v. Pettyjohn
64 A.3d 1072
| Pa. Super. Ct. | 2013Background
- Appellant Monroe Pettyjohn was convicted by a bench trial of three burglaries and related offenses arising from incidents in northwest Philadelphia.
- First burglary involved a 5031 Germantown Avenue deli where a door was open and lock broken; Appellant was found nearby with a crowbar, screwdriver, and mesh.
- Second burglary at 155 West Walnut Lane where front doors were kicked in and DVDs were found; fingerprint on a DVD matched Appellant.
- Third burglary at 23 West Walnut Lane where back patio doors were broken and a laptop was stolen; fingerprint found on the back door, and Handrich identified Appellant as having previously approached him.
- Trial court convicted on all charges on May 24, 2011; aggregate sentence was eight to sixteen years with seven years of probation.
- On appeal, Pettyjohn argues only that the fingerprint evidence was insufficient to prove two residential burglaries.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether fingerprint evidence suffices to prove two residential burglaries | Pettyjohn asserts fingerprints do not prove identity. | Pettyjohn (as the defense) contends innocent explanations exist for prints found. | Convictions upheld; fingerprints sufficient. |
Key Cases Cited
- Commonwealth v. Price, 420 A.2d 527 (Pa. Super. 1980) (fingerprints on nearby object can sustain burglary conviction if no innocent explanation)
- Commonwealth v. Cichy, 323 A.2d 817 (Pa. Super. 1974) (innocent presence on movable object may negate or sustain depending on circumstances)
- Commonwealth v. Wilson, 392 A.2d 769 (Pa. Super. 1978) (no logical explanation for prints on interior items supports conviction)
- In re M.J.H., 988 A.2d 694 (Pa. Super. 2010) (public-location prints with innocent contact may negate guilt)
- Commonwealth v. Donohue, 62 A.3d 1033 (Pa. Super. 2013) (upholds burglary conviction when fresh prints at entry support guilt; discusses fingerprint sufficiency framework)
- Commonwealth v. Marrero, 914 A.2d 870 (Pa. Super. 2006) (fingerprints on interior object can sustain if no innocent explanation)