Commonwealth v. Travaglia, 28 A.3d 868

January 3, 1980: Officer Leonard Miller is killed during a stop of a silver Lancia linked to Travaglia, Lesko, and Rutherford; six rounds fired from a .38 revolver.
Prior to Miller’s death, police link Travaglia to other robberies/murders; a homicide victim’s vehicle is found near Travaglia and Montgomery.
January 1981: Travaglia and Lesko are convicted of first-degree murder and conspiracy for Miller’s death; both are sentenced to death on direct appeal.
Post-conviction: PCHA relief denied; PCRA relief denied; federal habeas grants a new sentencing hearing due to evidence issues; resentencing occurs in 2000 and 2005.
Second penalty hearing (July 2005): jury imposes death sentence based on the officer-killed-in-the-line-of-duty aggravator outweighing two statutory mitigating factors (well-adjusted inmate; Christian life).
Appellant challenges numerous evidentiary rulings and statutory questions under 42 Pa.C.S. § 9711; the Pennsylvania Supreme Court affirms the death sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Evidentiary admissibility of prison-adjustment testimony	Travaglia argues Miller’s testimony on future adjustment was admissible as mitigating per Skipper.	Court properly limited speculative, irrelevant testimony under Rule 602.	Harmless error; exclusion upheld.
Admission of other mitigating evidence	Three witnesses’ mitigation evidence was improperly curtailed.	Evidence was adequately presented through other available means.	No relief; evidence eventually admitted or rendered moot.
Positive prison-adjustment evidence is rebuttable	Be allowed to rebut with pre-incarceration crimes as non-character evidence.	Positively framed as rebuttal to good-character evidence.	Appellant not entitled to relief; rebuttal permitted.
Admission of Nichols’ guilty-plea evidence	Mistrial should have been granted due to improper mention of Nichols plea.	No mistrial; federal order limited use; testing of witnesses allowed.	No reversible error; mistrial unnecessary.
Beasley/Beasley-type scope of prior-conviction evidence	Beasley limits on facts surrounding prior convictions should apply to preclude extraneous details.	Beasley permits contextual facts to rebut mitigation; not limited to aggravation context.	Beasley supports admissibility of surrounding facts to rebut good-character evidence; no relief.

Skipper v. South Carolina, 476 U.S. 1 (1986) (prison adjustment evidence may be mitigating if admissible and relevant)
Commonwealth v. Fisher, 559 Pa. 558, 741 A.2d 1234 (2000) (prosecutor may test good-character evidence; tattoos cross-examination example)
Commonwealth v. Beasley, 505 Pa. 279, 479 A.2d 460 (1984) (convictions may include surrounding circumstances when assessing aggravation/character)
Commonwealth v. Jones, 542 Pa. 464, 668 A.2d 491 (1995) (harmless error when improperly admitted aggravating evidence not relied on by jury)
Commonwealth v. McPhail, 547 Pa. 519, 692 A.2d 139 (1997) (jurisdiction and res judicata aspects of murder prosecutions in multiple counties)