Commonwealth v. Ramtahal
33 A.3d 602
| Pa. | 2011Background
- Ramtahal was sentenced to death after a jury convicted him of first-degree murder, criminal conspiracy, two counts of possessing an instrument of crime, and three counts of robbery in Bucks County.
- On November 15, 2006, he and Nyako Pippen targeted three men in Winder Village, Bristol Township, suspected of drug dealing with money to rob.
- They armed themselves, concealed identities, and approached the victims; a shotgun jammed, and a handgun was fired at about seventy feet, injuring Jarrett Osborne and leading to his death.
- Forensic evidence linked the Kel-Tec handgun, a ski mask, and DNA from the mask to Ramtahal; DNA from a search warrant sample matched the ski mask and handgun.
- Cellular telephone records showed movements toward and around Winder Village on the night of the shooting; Pippen testified to the plan and the events.
- Defense argued lack of premeditation due to alleged firearm- barrel alterations; the jury nevertheless found Ramtahal guilty of first-degree murder and returned a death sentence with aggravating factors and a single mitigating factor.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence supports first-degree murder | Ramtahal | Ramtahal | Evidence supports premeditated murder |
| Whether the verdict was against the weight of the evidence | Ramtahal | Ramtahal | No abuse of discretion; weight claim rejected |
| Whether cross-examination of Detective Beidler was improperly limited | Ramtahal | Commonwealth | Court did not abuse discretion; hearsay issue properly ruled |
| Whether the penalty-phase verdict form required non-statutory mitigators to be listed and whether a new penalty hearing is required | Ramtahal | Commonwealth | Waived; no new penalty hearing required |
Key Cases Cited
- Commonwealth v. Smith, 985 A.2d 886 (Pa. 2009) (sufficiency can be proven by circumstantial evidence)
- Commonwealth v. Laird, 988 A.2d 618 (Pa. 2010) (jury may assess credibility and weigh evidence)
- Commonwealth v. Diggs, 949 A.2d 878 (Pa. 2008) (weight of the evidence is appellate-discretion issue)
- Commonwealth v. Cousar, 928 A.2d 1025 (Pa. 2007) (weight-of-the-evidence review limits)
- Commonwealth v. Rivera, 983 A.2d 1211 (Pa. 2009) (scope of cross-examination discretionary)
- Commonwealth v. Diggs, 949 A.2d 878 (Pa. 2008) (weight-of-the-evidence standard cited)