Commonwealth v. Stiles
143 A.3d 968
Pa. Super. Ct.2016Background
- Appellant Rafik Stiles (17 at time of offenses) was tried jointly and convicted of two counts of first‑degree murder and two VUFA counts for killings on July 4, 2010 (Kyle Featherstone) and July 10, 2010 (Barbara Crowder); aggregate sentence 40 years to life.
- Ballistics testing showed bullets from both crime scenes were fired from the same .38/.357 firearm.
- Identification evidence included: statements/testimony from Katrina Session (Appellant’s sister) and others, a photo array identification by Bernard Lewis and Parrish Grantham (who later recanted/unavailable), and inculpatory statements to cellmate Zachary Neugent.
- Appellant moved to suppress the photographic array (arguing it was unduly suggestive because his photo showed dreadlocks while witnesses described a clean‑shaven shooter) and moved to sever the two cases; both motions were denied.
- Appellant challenged consolidation, the photo array, the weight of the evidence, and sufficiency of the evidence on appeal. The Superior Court affirmed; some issues were deemed waived for procedural record deficiencies.
Issues
| Issue | Stiles' Argument | Commonwealth/Trial Court Argument | Held |
|---|---|---|---|
| Whether the court erred by consolidating the two murders for one trial | Consolidation improperly admitted Crowder ballistics to prejudice the Featherstone case; the Crowder evidence was cumulative/unnecessary because eyewitness ID and confession evidence sufficed | Ballistics tying the same gun to both crimes was probative of identity and admissible; jury can separate the two crimes; limiting instructions given | Affirmed — joinder proper; probative value of shared‑weapon evidence outweighed prejudice; no demonstrated jury confusion |
| Whether photographic array was unduly suggestive and should be suppressed | Photo showed Stiles with dreadlocks (taken later) unlike witnesses’ descriptions; array likely to cause misidentification | Array did not make Stiles’ photo stand out; all photos had similar features; witnesses said shooter wore a hat; suppression hearing record did not show impermissible suggestiveness | Affirmed — suppression issue waived for incomplete record but merit review found no undue suggestiveness; identification admissible |
| Whether verdicts were against the weight of the evidence | Witnesses were inconsistent, recanted, and unreliable; verdict shocks sense of justice | Credibility determinations are for the jury; testimony supported identifications; trial court saw evidence and denied new trial | Affirmed — no abuse of discretion; jury entitled to credit witnesses despite inconsistencies |
| Whether evidence was insufficient to sustain convictions | Eyewitness and circumstantial inferences were unreliable; identity not proven beyond reasonable doubt | Ballistics, identifications, and admissions (to Neugent) provided sufficient direct and circumstantial proof of identity and intent | Not reached on merits — sufficiency claim waived for failure to specify elements in 1925(b) statement; court also indicated evidence would have been sufficient |
Key Cases Cited
- Commonwealth v. Wholaver, 989 A.2d 883 (Pa. 2010) (standard for joinder and abuse of discretion review)
- Commonwealth v. Cousar, 928 A.2d 1025 (Pa. 2007) (evidence of other crimes admissible to prove identity where proof of one crime tends to prove the other)
- Commonwealth v. Reid, 626 A.2d 118 (Pa. 1993) (weapon used in two incidents admissible to identify shooter)
- Commonwealth v. Rollins, 580 A.2d 744 (Pa. 1990) (evidence of similar shooting days apart admissible for identity)
- Commonwealth v. Fulmore, 25 A.3d 340 (Pa. Super. 2011) (undue suggestiveness standard for photo arrays; differences go to weight not admissibility)
- Commonwealth v. Davis, 17 A.3d 390 (Pa. Super. 2011) (photo array suggestiveness arises when suspect’s picture is singled out)
- Commonwealth v. Sanders, 42 A.3d 325 (Pa. Super. 2012) (pretrial ID reliability issues affect weight not admissibility)
- Commonwealth v. Widmer, 744 A.2d 745 (Pa. 2000) (standard of review for weight of the evidence claims)
- Commonwealth v. Talbert, 129 A.3d 536 (Pa. Super. 2015) (sufficiency review statement of law)
- Commonwealth v. Garland, 63 A.3d 339 (Pa. Super. 2013) (Rule 1925(b) requirement: specificity for sufficiency claims)
- Commonwealth v. Martz, 926 A.2d 514 (Pa. Super. 2007) (appellant’s failure to include necessary materials in certified record can waive review)