Commonwealth v. Sanchez
614 Pa. 1
Pa.2011Background
- Appellant Abraham Sanchez, Jr. was convicted of first-degree murder, robbery, and conspiracy; death sentence imposed after trial by jury in 2009.
- At trial, the Commonwealth presented eyewitness and accomplice testimony plus physical and documentary evidence tying Sanchez to the murder.
- Sanchez challenged sufficiency and weight of the evidence, Batson, and various trial conduct issues, including Atkins v. Virginia (mental retardation) timing.
- The trial court sentenced Sanchez to death, with a single aggravator for robbery; multiple mitigators were rejected.
- On direct appeal, the Pennsylvania Supreme Court affirms the convictions and sentence and develops an Atkins implementation procedure.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for first‑degree murder | Sanchez argues co‑defendant testimony is unreliable and insufficient. | Commonwealth contends evidence, including confessions and corroboration, supports guilt beyond a reasonable doubt. | Sufficiency established; guilt supported. |
| Batson challenge to juror strike | Commonwealth struck an African‑American death‑qualified juror (#34) for race. | Prosecution provided race‑neutral reasons; burden shifting shows no purposeful discrimination. | No Batson violation; strike upheld. |
| Timing and scope of Atkins (mental retardation) adjudication | Issue should have been decided pretrial by judge and not by jury at penalty phase. | States may vary; jury determination permitted; burden placement and timing are flexible. | Jury determination at penalty phase approved; no pretrial bench requirement established; burden on defendant by preponderance. |
| Emotional outbursts by victim's family | Trial court failed to remove or admonish sobbing family members, prejudicing defense. | Outbursts were brief; no objective prejudice shown and no curative instruction requested. | No abuse of discretion; no reversible prejudice. |
| Admission of photographs and victim's clothing | Photos and clothing were inflammatory and lacked probative value beyond shock value. | Evidence was relevant to scene, sequence, and ballistics; redacted photos shown with no objection; clothing aids expert. | No reversible error; photographs and clothing properly admitted under rules of evidence. |
Key Cases Cited
- Commonwealth v. Miller, 585 Pa. 144 (Pa. 2005) (Atkins standard for mental retardation in PA capital cases)
- Commonwealth v. Bracey, 604 Pa. 459 (Pa. 2009) (PCRA Atkins proceedings; bifurcation guidance)
- Commonwealth v. Vandivner, 599 Pa. 617 (Pa. 2009) (Atkins and burden allocation in PA capital cases)
- Commonwealth v. DeJesus, 580 Pa. 303 (Pa. 2004) (weight versus sufficiency distinction in sufficiency review)
- Commonwealth v. Farquharson, 467 Pa. 50 (Pa. 1976) (unreliability/contradiction grounds for weight‑of‑the‑evidence challenges)
- Atkins v. Virginia, 536 U.S. 304 (U.S. 2002) (constitutional prohibition on execution of mentally retarded)