Commonwealth v. Pruitt, M., Aplt.
Commonwealth v. Pruitt, M., Aplt. - No. 727 CAP
| Pa. | Jun 20, 2017Background
- Michael Pruitt convicted of first-degree murder, robbery, burglary, rape, and IDSI; sentenced to death. Post-conviction review raised ineffective-assistance claims.
- At trial Commonwealth forensic scientist Lisa Mihalacki testified that sperm-fraction STR results perfectly matched Pruitt and reported astronomically low population odds.
- Mihalacki's laboratory report, however, recorded no data at three sperm-fraction loci and deemed five loci inconclusive; her trial testimony overstated and contradicted her report.
- Trial counsel admitted he did not understand the DNA data and did not retain a DNA expert or highlight the report’s inconsistencies at trial.
- Post-conviction expert Dr. Randal Libby examined the data and slides, found essentially undetectable DNA and no confirmable sperm, identified testing inconsistencies (including potential exclusion at FGA), and concluded the DNA evidence was inconclusive.
- Justice Wecht (dissenting) agrees counsel performed deficiently and would find prejudice because undermining the DNA evidence likely would have affected both culpability for the sexual offenses and the penalty-phase weighing that produced the death sentence.
Issues
| Issue | Pruitt's Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Whether trial counsel was constitutionally ineffective for failing to investigate/challenge DNA evidence | Counsel had no reasonable basis; should have consulted an expert and exposed Mihalacki's inconsistencies | No reasonable probability of a different outcome because Pruitt's identity as robber/killer was not seriously contested | Dissent (Wecht): Counsel was deficient; would find prejudice and remand for further proceedings |
| Whether Mihalacki’s DNA testimony was reliable | DNA analysis was unreliable and overstated; population statistics inapplicable given inconclusive loci and low-template DNA | Mihalacki’s testimony and statistics supported inclusion of Pruitt as source | Dissent: DNA testing was inconclusive; testimony overstated reliability |
| Whether challenging the DNA would have affected guilt for sexual offenses | Effective challenge would have created reasonable doubt about Pruitt as rapist (other person present) | Even without DNA, other evidence and Pruitt’s statement support verdicts | Dissent: DNA was the sole physical link to sexual offenses; effective challenge could have created reasonable doubt |
| Whether any change to sexual-offense findings would have altered penalty-phase outcome | Rebutting the rape/IDSI convictions would have weakened the single statutory aggravator and could have led to life sentence | Jury already found felony-murder aggravator based on burglary/robbery; outcome likely unchanged | Dissent: Loss of the particularly inflammatory sexual-offense aggravation likely would have reduced weight of the sole aggravator and could have changed sentence |
Key Cases Cited
- Commonwealth v. Blasioli, 713 A.2d 1117 (Pa. 1998) (general background on DNA and STR analysis)
- Commonwealth v. Laird, 119 A.3d 972 (Pa. 2015) (ineffective-assistance legal standard)
- Commonwealth v. Daniels, 104 A.3d 267 (Pa. 2014) (discussion of qualitative weighing of aggravating and mitigating evidence)
- Commonwealth v. Tharp, 101 A.3d 736 (Pa. 2014) (context for weighing in capital penalty phase)