Commonwealth v. Stahl
175 A.3d 301
| Pa. Super. Ct. | 2017Background
- October 2014: Victim drank at bars and was driven home by Cody Stahl (Appellant) and Robert Kachur; the three engaged in a sexual encounter.
- Victim testified she was highly intoxicated, vomited, had gaps in memory, briefly woke during the encounter (felt pain), passed out again, and woke the next morning — asserting she was unconscious/unaware during the sexual acts.
- Kachur pleaded to charges and testified for the Commonwealth but largely supported Stahl’s version that the victim was conscious and instigated the encounter.
- Stahl was charged with rape, involuntary deviate sexual intercourse, aggravated indecent assault, and indecent assault (all alleging unconsciousness/unawareness or lack of consent).
- Trial ended in a hung jury and mistrial; Stahl filed a timely motion for judgment of acquittal challenging sufficiency of the Commonwealth’s evidence. Trial court denied the motion; Stahl appealed under Pa.R.A.P. 311(a)(6).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Commonwealth’s evidence was insufficient to prove unconsciousness/unawareness beyond a reasonable doubt | Commonwealth: Victim’s testimony that she was unconscious/unaware was sufficient to meet its burden | Stahl: Kachur’s testimony contradicted the victim; evidence equivocal so sufficiency review should not favor the Commonwealth because there was no jury “verdict-winner” | Court: Evidence sufficient; victim’s testimony, if believed, established unconsciousness/unawareness; conflicts with Kachur go to weight, not sufficiency |
| Whether the usual sufficiency standard (view evidence in light most favorable to verdict-winner) applies after a mistrial | Commonwealth: Standard applies; “verdict-winner” language is just shorthand for the prosecution | Stahl: Because jury deadlocked, court should not treat evidence as to be viewed in the light most favorable to the Commonwealth | Court: Rejected Stahl’s novel argument; standard remains the same — view evidence (and reasonable inferences) favorably to the Commonwealth; presence/absence of a jury verdict does not alter the legal sufficiency test |
Key Cases Cited
- Widmer v. Commonwealth, 744 A.2d 745 (Pa. 2000) (articulates standard for sufficiency review: view evidence in light most favorable to prosecution)
- Emanuel v. Commonwealth, 86 A.3d 892 (Pa. Super. 2014) (motion for judgment of acquittal challenges sufficiency and is granted only if Commonwealth failed to carry burden)
- Gaskins v. Commonwealth, 692 A.2d 224 (Pa. Super. 1997) (credibility conflicts go to weight, not sufficiency)
- Duncan v. Commonwealth, 373 A.2d 1051 (Pa. 1977) (sufficiency test: accept prosecution's evidence and reasonable inferences)
- Hankins v. Commonwealth, 380 A.2d 415 (Pa. Super. 1977) (sufficiency review accepts Commonwealth evidence and reasonable inferences)
- U.S. v. Austin, 585 F.2d 1271 (5th Cir. 1978) (sufficiency test applies uniformly whether judged at close of evidence, after verdict, or on motion after mistrial)
- Commonwealth v. Arnold, 258 A.2d 885 (Pa. Super. 1969) (Commonwealth cannot appeal an acquittal)