Commonwealth v. Wright
14 A.3d 798
| Pa. | 2011Background
- Wright, convicted of rape and murder of Louise Talley, sought postconviction DNA testing under 42 Pa.C.S.A. § 9543.1 after various trial evidentiary issues.
- A prior suppression ruling deemed Wright’s confession voluntary and the confession was admitted at trial.
- He requested STR DNA testing on specific evidence (semen, bloodstains, underwear-related items, and autopsy swabs) to support innocence claims.
- Lower courts applied a per se bar based on a consensual or voluntary confession, relying on Commonwealth v. Young.
- The Pennsylvania Supreme Court granted review to determine whether a voluntary confession bars DNA testing under § 9543.1 and whether Young should be overruled.
- The Court ultimately held that a voluntary confession is not a per se bar to establishing a prima facie case for DNA testing and remanded for consideration of Wright’s prima facie case and the statutory requirements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a voluntary confession precludes DNA testing under § 9543.1(c)(3). | Wright argues voluntariness should not bar testing; testing could prove actual innocence. | Commonwealth contends the prior voluntariness ruling should bar testing under Young. | Not a per se bar; confession does not automatically bar testing. |
| Whether the Superior Court's Young ruling was correct and should be overruled. | Young improperly precludes testing based on a final voluntariness ruling. | Young follows from a narrow reading of § 9543.1 to protect final court determinations. | Overruled; Young is disavowed, and Wright may proceed with testing. |
| What remains to be determined on remand under § 9543.1(d)(2)(i) and (c)(3) after overruling Young. | There may be a reasonable possibility that testing would show actual innocence. | Testing may still be unlikely to exculpate given other strong incriminating evidence. | Remand to assess prima facie case and potential exculpatory impact consistent with statute. |
Key Cases Cited
- Commonwealth v. Young, 873 A.2d 720 (Pa.Super.2005) (ruling that a confession precludes DNA testing under § 9543.1)
- Starr v. Starr, 541 Pa. 564, 664 A.2d 1326 (1995) (law of the case considerations; finality does not bind DNA testing inquiry)
- Connelly, 479 U.S. 157 (1986) (voluntariness analysis requires totality of circumstances, not truth of statements)
- Crane v. Kentucky, 476 U.S. 683 (1986) (confession not automatically conclusive of guilt; jury decides truth)
- Yarris v. County of Delaware, 465 F.3d 129 (3d Cir.2006) (DNA testing exculpatory, leading to exoneration after conviction)
- Godschalk v. State, 451 Pa. Super. 425, 679 A.2d 1295 (1996) (early exoneration cases cited in DNA testing context)
- Commonwealth v. Sherwood, 603 Pa. 92, 982 A.2d 483 (2009) (reflects jury authority to assess confession credibility)
- Commonwealth v. McClintic, 589 Pa. 465, 909 A.2d 1241 (2006) (statutory interpretation standards; de novo review for legal questions)