Commonwealth v. Ward, 188 A.3d 1301

Background

On Jan 23, 2014, Jason Eubanks and Cheralynn Sabatasso were found shot to death in Sabatasso’s Lexus in Pittsburgh; tracks led to 302 Rochelle St., where Antoine Ward lived.
Ward was tried and convicted of first- and third-degree murder and carrying a firearm without a license; court imposed consecutive life sentences and an additional term for the firearm offense.
Ward testified he was in the Lexus to buy cocaine, struggled with Eubanks over a gun, and shot in self-defense; he admitted hiding a gun and bloody clothing and gave inconsistent pretrial statements.
Physical evidence included bullets in a sock and bloody clothing recovered near Ward’s street and a pistol found under a kitchen cabinet at Ward’s residence; medical testimony described a shot fracturing Eubanks’s skull.
The Lexus was processed by police, then released to the family and later sold to a salvage yard; ultimately the vehicle was sold overseas before defense experts could fully inspect it.
Ward appealed, raising three principal claims: insufficiency of the Commonwealth’s disproof of self-defense, suppression/denial of access to the Lexus (spoliation), and improper/expert testimony beyond report scope or expertise.

Issues

Issue	Commonwealth's Argument	Ward's Argument	Held
Sufficiency: did Commonwealth disprove self-defense beyond reasonable doubt?	Evidence of Ward’s inconsistent statements, attempts to conceal evidence, and medical testimony showing first shot likely fatal permitted jury to reject self-defense.	Ward argued his testimony established self-defense (struggle over the gun) and Commonwealth failed to rebut.	Affirmed. Commonwealth sufficiently disproved self-defense based on false statements, concealment, and medical evidence undermining Ward’s account.
Suppression/spoliation: should evidence from Lexus be excluded because vehicle was sold abroad before defense inspection?	The vehicle was available for substantial time; its loss was not the product of bad faith by police/prosecution but resulted from sale by owner/insurer and Coparts; negligence does not equal bad faith.	Ward argued the Lexus was the crime scene and its loss deprived defense of potentially exculpatory evidence and meaningful opportunity to present a complete defense.	Affirmed. Loss was at most negligent and evidence was potentially useful (not clearly exculpatory); no bad faith shown, so no due process violation.
Expert testimony: did the medical examiner testify beyond his report or expertise (trajectory, range, fatality)?	Dr. Xu was a qualified forensic pathologist; his opinions on wound trajectory, range, and likely fatality were within expertise and grounded in autopsy findings; any scope issues caused no prejudice.	Ward contended Dr. Xu testified outside his report and beyond expertise (distance, trajectory, that first shot was fatal).	Affirmed. Trial court did not abuse discretion; testimony rested on factual basis and did not prejudice Ward.

Key Cases Cited

Commonwealth v. Carbone, 574 A.2d 584 (Pa. 1990) (false or inconsistent statements may support inference of guilt against self-defense claim)
Commonwealth v. Bullock, 948 A.2d 818 (Pa. Super. 2008) (Commonwealth must disprove self-defense beyond a reasonable doubt once raised)
Commonwealth v. Chamberlain, 30 A.3d 381 (Pa. 2011) (distinguishes materially exculpatory evidence from potentially useful evidence; bad faith required for due process violation when potentially useful evidence is lost)
California v. Trombetta, 467 U.S. 479 (1984) (police duty to preserve evidence; destruction of potentially useful evidence gives rise to due process violation only on showing of bad faith)
Arizona v. Youngblood, 488 U.S. 51 (1988) (negligent failure to preserve evidence does not violate due process absent bad faith)
Commonwealth v. Spotz, 756 A.2d 1139 (Pa. 2000) (expert may give opinion grounded in facts without reciting formulaic phrase that opinion meets reasonable degree of medical certainty)