Commonwealth v. Poplawski, R., Aplt., 130 A.3d 697

Appellant Richard Poplawski killed three Pittsburgh police officers during an April 4, 2009 attack at his home and engaged in a prolonged gun battle with responding officers.
He equipped himself with body armor and multiple firearms, initiating an ambush as officers entered; the attack killed Officers Sciullo, Mayhle, and Kelly.
Following the standoff, Appellant surrendered, was Mirandized, and later provided a detailed written and oral confession about the killings.
A jury convicted him of three counts of first-degree murder and related offenses; the penalty phase resulted in three death sentences.
Appellant filed a direct appeal challenging evidentiary rulings, suppression rulings, and prosecutorial conduct, among other issues; the Pennsylvania Supreme Court affirmed the judgments of sentence.
The Court conducted statutory review and upheld the death sentences citing multiple aggravating factors outweighing mitigators.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for first-degree murder	Poplawski	Poplawski	Sufficient evidence supported three counts of first-degree murder
Admissibility and voluntariness of hospital statements	Poplawski invoked right to counsel; later statements were involuntary	Police honored invocation; waiver was voluntary	Denial of suppression affirmed; statements admissible
Admission of racial epithets from 911 and related records	Epithets were irrelevant and prejudicial	Contextual and probative; not outcome-determinative	Harmless error; not capable of contributing to guilt or penalty
Discovery violations by expert testimony beyond reports	Experts testified beyond pretrial disclosures	Testimony were necessary for understanding complex evidence	Harmless error; cumulative and cross-examination diminished prejudice
Admission of StormFront website visitation evidence	Evidence shows racist/anti-government beliefs relevant to context	Beliefs not probative; violates due process	Waived for guilt phase; no reversal in penalty phase; admissible for contextual history

Commonwealth v. Johnson, 985 A.2d 915 (Pa. 2009) (convincing inference of intent from deadly weapon use (first-degree murder))
Commonwealth v. Sanchez, 82 A.3d 943 (Pa. 2013) (sufficiency review in capital direct appeal)
Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (right to counsel; invocation and subsequent interrogation standards)
Commonwealth v. Hubble, 504 A.2d 175 (Pa. 1986) (two-pronged test for voluntary waiver after invocation)
Dawson v. Delaware, 503 U.S. 159 (U.S. 1992) (First Amendment concerns with evidence of beliefs in penalty phase)
Commonwealth v. Keaton, 45 A.3d 1050 (Pa. 2012) (invocation shields arrestee from interrogation until counsel present)
Commonwealth v. Eichinger, 108 A.3d 821 (Pa. 2014) (future dangerousness discussions allowed with proper instructions)
Payne v. Tennessee, 501 U.S. 808 (U.S. 1991) (victim-impact evidence permissible under Payne framework)
Dawson v. Delaware, 112 S. Ct. 1090 (U.S. 1992) (distinguishes abstract beliefs from relevant evidence in penalty phase)