Commonwealth v. Woodard, A., Aplt.
129 A.3d 480
| Pa. | 2015Background
- On Nov. 7, 2011 two-year-old Jaques Twinn was found unresponsive after being left in Aric Woodard’s care; he died at the hospital. Appellant conceded disciplining the child (slapping, pulling by the ear) and leaving him in a bathtub; he later gave recorded statements repeating those facts.
- Autopsy by Dr. Samuel Land showed multiple recent bruises across the body, a near-complete laceration of the liver (hours before death), bilateral subdural hemorrhages, and other injuries; cause of death: multiple blunt force trauma (homicide). Defense experts disputed timing/cause (drowning, CPR-related liver injury).
- Police briefly entered Appellant’s residence to check for other children and to fetch diapers before obtaining and executing a corrected search warrant; photographs and items (belt pieces, electronics, drug paraphernalia, clothing) were seized after the valid warrant.
- Appellant gave three recorded statements (Nov. 7, Nov. 11, 2011, and March 20, 2012). Suppression motions argued Miranda/Edwards (Nov. 11) and Sixth Amendment (Mar. 20). Trial court denied suppression.
- Jury convicted Appellant of first-degree murder. At penalty phase the Commonwealth relied on two aggravators: (d)(16) victim under 12 (stipulated) and (d)(8) torture (incorporating trial record). Jury returned death sentence. This direct appeal raises sufficiency, evidentiary, suppression, search, and sentencing claims.
Issues
| Issue | Appellant’s Argument | Commonwealth / Trial Court Argument | Held |
|---|---|---|---|
| Sufficiency — specific intent for 1st‑degree murder | No direct eyewitness or single fatal blow; conduct could be transient rage without intent to kill; efforts to seek aid show lack of intent | Medical evidence of repeated, severe blows (liver laceration, subdural hemorrhages) during Appellant’s exclusive care supports inference of deliberate, prolonged abuse showing intent | Conviction affirmed — evidence sufficient to infer specific intent from totality of conduct (cites Powell/Chambers) |
| Admissibility of autopsy photos | Photos inflammatory and cumulative; Dr. Land’s testimony alone would suffice | Photos necessary to distinguish preexisting skin findings and to rebut accidental drowning; probative value outweighs prejudice | Photos admissible; trial court did not abuse discretion |
| Jury access to medical reports/records during deliberations | Complex medical materials required expert interpretation; possible hearsay/confrontation problems if jury relied on non‑testified portions | Pa. R. Crim. P. 646 permits exhibits the judge deems proper; both sides’ expert reports and records were admitted and experts testified | No abuse of discretion; defendant waived objection to some items; no prejudice shown |
| Nov. 11, 2011 statement — Miranda/Edwards invocation | Appellant mentioned attorney warned him not to speak — this was an invocation requiring cessation of questioning | Statement was ambiguous reference to counsel in an unrelated matter; Appellant expressly waived counsel and said no lawyer needed; not in custody | Suppression denied — no unambiguous invocation of right to counsel; waiver found valid |
| Mar. 20, 2012 statement — Sixth Amendment | Appellant argues waiver invalid because police did not explicitly tell him he could stop interrogation and request counsel | Appellant received Miranda warnings, said he understood, and affirmatively chose to speak | Suppression denied — knowing, voluntary waiver of rights; statement admissible |
| Search of residence / fruit of prior entry | Initial warrantless entries tainted later warrant; evidence seized after warrant must be suppressed | Initial entries were limited, caretaking welfare checks (no evidence seized); corrected warrant obtained and executed; affidavit independent of any prior entry | Evidence admitted — no unlawful search prior to warrant, and warrant supported by probable cause |
| Torture aggravator (pretrial quash & proof at penalty) | No evidence victim was conscious during repeated blows; speculation that pain was experienced when unconscious defeats torture element | Medical testimony showed numerous impacts, lacerated liver causing severe pain over hours, and later fatal head injury; intent/timing can be inferred from circumstances | Aggravator submitted and proved beyond reasonable doubt — sufficient evidence of intentional infliction of considerable pain (torture) |
| Death‑qualified jury / separate juries for guilt and penalty | Death‑qualification skews jury toward conviction; separate non‑death‑qualified jury needed for penalty | Supreme Court and Pennsylvania precedent permit death‑qualification; Sentencing Code requires same jury for guilt and penalty | Claims rejected — death‑qualification and same‑jury requirement constitutional and properly applied |
Key Cases Cited
- Commonwealth v. Chambers, 980 A.2d 35 (Pa.) (continued pattern of child abuse can support specific intent and torture aggravator)
- Commonwealth v. Powell, 956 A.2d 406 (Pa.) (no requirement of a single final fatal blow to prove specific intent; prolonged abuse can show intent and torture)
- Commonwealth v. Smith, 675 A.2d 1221 (Pa.) (child‑abuse killings with multiple injuries supported torture finding)
- Commonwealth v. Wade, 389 A.2d 560 (Pa.) (autopsy photographs admissible to show extent of injuries and rebut accidental theories)
- Commonwealth v. Murray, 83 A.3d 137 (Pa.) (framework for assessing inflammatory photographs and balancing probative value)
- Lockhart v. McCree, 476 U.S. 162 (U.S.) (death‑qualification of jurors constitutionally permissible)
- Davis v. United States, 512 U.S. 452 (U.S.) (invocation of right to counsel must be unambiguous)
- Miranda v. Arizona, 384 U.S. 436 (U.S.) (custodial interrogation warnings and waiver principles)
- Segura v. United States, 468 U.S. 796 (U.S.) (evidence seized pursuant to a valid warrant later may be admissible even if earlier police entry was unlawful)