Commonwealth v. Williams
154 A.3d 336
| Pa. Super. Ct. | 2017Background
- On Sept. 20, 2015, Empire Pizza was burglarized; surveillance cameras recorded the incident and police viewed the footage at the scene.
- Officer Sweeney identified Leroy DePree Williams as the suspect after viewing the video with proprietor Amar Jasarevic.
- Jasarevic attempted to copy the footage for police but the original video was lost/deleted (hard drive malfunction or inadvertent erasure), so no copy exists and Williams never saw the recording.
- Williams moved to dismiss (and/or suppress) on best-evidence and due-process/spoliation grounds; an evidentiary hearing was held.
- The trial court found no bad faith (so no best-evidence bar), but concluded the lost video could be materially exculpatory and suppressed any testimony describing the video’s content as fundamentally unfair.
- The Commonwealth appealed; the Superior Court reviewed whether suppression was legally required given the loss of the footage.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Williams) | Held |
|---|---|---|---|
| Whether testimony about the lost surveillance video must be suppressed under due process/spoliation principles | The video was only "potentially useful," not manifestly exculpatory; suppression improper because police did not act in bad faith | Loss deprived Williams of the ability to view potentially exculpatory material and testimony about the video’s content would be fundamentally unfair | Reversed suppression: evidence is not shown to be materially exculpatory but only potentially useful; absent bad faith, testimony about the video is admissible |
Key Cases Cited
- Commonwealth v. Korn, 139 A.3d 249 (Pa. Super. 2016) (standard of review for suppression appeals)
- Commonwealth v. Chamberlain, 30 A.3d 381 (Pa. 2011) (distinguishes "materially exculpatory" from "potentially useful" evidence and requires bad faith for the latter)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose materially exculpatory evidence)
- United States v. Agurs, 427 U.S. 97 (1976) (Brady related holdings on exculpatory evidence disclosure duties)
- Commonwealth v. Spotti, 94 A.3d 367 (Pa. Super. 2014) (pure speculation that lost evidence might have been exculpatory does not establish materiality)
- Commonwealth v. Colavita, 993 A.2d 874 (Pa. 2010) (appellate courts generally cannot decide issues not preserved or raised by parties)