Commonwealth v. Quiles
166 A.3d 387
| Pa. Super. Ct. | 2017Background
- On Oct. 24, 2013, Quiles and a co-defendant engaged in a pre-arranged heroin sale at a Pike County gas station; Quiles was arrested after the controlled buy.
- Quiles was Mirandized in English, signed a written waiver and consent-to-search forms (car and cellphone), and was interviewed by detectives in English; Quiles later claimed limited English and heroin intoxication at the time.
- Quiles moved to suppress his statements and the evidence from his phone/car, arguing he did not understand English and was under the influence; the suppression court denied the motion after an evidentiary hearing and review of the interrogation recording.
- A jury convicted Quiles of two counts of Delivery of a Controlled Substance and one count of Criminal Conspiracy to Deliver a Controlled Substance; the trial court sentenced him to 9–30 years.
- At sentencing the trial court found Quiles ineligible for RRRI based on a prior Connecticut conviction for Assault (classified in Connecticut as an M-A / Assault in the Third Degree); Quiles appealed both the suppression ruling and RRRI ineligibility.
- The Superior Court affirmed the convictions (finding the suppression factual findings supported by the record) but vacated the sentence and remanded for resentencing because the trial court improperly relied on the Connecticut assault conviction when determining RRRI eligibility.
Issues
| Issue | Plaintiff's Argument (Quiles) | Defendant's Argument (Commonwealth) | Held |
|---|---|---|---|
| Whether Quiles’s Miranda waiver and consent to search were voluntary | Quiles argued he was under heroin influence and lacked sufficient English to knowingly waive Miranda or consent to searches | Commonwealth relied on officer testimony, the recorded interview, signed written waivers/consents, and Quiles’s demonstrated English comprehension | Suppression denial affirmed; court found waiver/consent voluntary and Quiles understood English and was not impaired |
| Whether record sufficiently shows a Connecticut conviction | Quiles argued the record did not establish conviction, statute, or equivalency | Commonwealth pointed to PSI showing an "Unconditional Discharge" for Assault (M-A) and Connecticut law treating that as a final conviction, permitting identification as Assault in the Third Degree | Court held PSI plus Connecticut law established a conviction for Assault in the Third Degree |
| Whether Connecticut Assault in the Third Degree is "substantially equivalent" to Pennsylvania Simple Assault for RRRI purposes | Quiles argued the out-of-state assault should not disqualify RRRI because record unclear and statutes may differ | Commonwealth treated the Connecticut conviction as a disqualifying personal-injury offense equivalent to Pennsylvania Simple Assault | Court held the statutes are not substantially equivalent because Pennsylvania’s Simple Assault has a statutory exception grading mutual-consent fights as 3rd-degree misdemeanors (preserving RRRI eligibility), while Connecticut’s statute lacks that distinction; trial court erred to rely on the Connecticut conviction for RRRI ineligibility |
Key Cases Cited
- Commonwealth v. Jones, 988 A.2d 649 (Pa. 2010) (standard of review for suppression denial)
- Commonwealth v. Northrip, 985 A.2d 734 (Pa. 2009) (non-equivalence where grading and policy differ between statutes)
- Commonwealth v. Barbaro, 94 A.3d 389 (Pa. Super. 2014) (use Northrip equivalence test for RRRI comparisons)
- Commonwealth v. Hansley, 47 A.3d 1180 (Pa. 2012) (court must determine RRRI eligibility when imposing state sentence)
- Florida v. Jimeno, 500 U.S. 248 (1991) (consent to search doctrine under Fourth Amendment)