# Commonwealth v. Arrington

> Supreme Court of Pennsylvania · February 28, 2014 · 624 Pa. 506

URL: https://www.frixlaw.com/law-library/cases/4968578

## Case

- **Full name:** COMMONWEALTH of Pennsylvania v. Lance ARRINGTON
- **Court:** Supreme Court of Pennsylvania
- **Decided:** February 28, 2014
- **Citations:** 624 Pa. 506; 86 A.3d 831; 2014 Pa. LEXIS 574; 2014 WL 783559
- **Precedential status:** Published
- **Opinion:** Dissent by Saylor
- **Judges:** Baer, Castille, Eakin, Files, McCaffery, Saylor, Stevens, Todd
- **Cited by:** 140 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4968578

## How later opinions describe it (automated extraction)

- holding evidence of defendant’s prior acts in past relationships was admissible to establish a common plan or scheme under Pa.R.E. 404(b)(2), where in each instance Arrington “(1) monitored his girlfriend’s daily activities; (2) resorted to violence when his partner wanted to …
- finding that the absence of a Simmons instruction did not violate appellant's due process rights "[i]n light of [his] counsel's lengthy explanation of the meaning of a life sentence, which clearly conveyed that [a]ppellant would be ineligible for parole under Pennsylvania law"
- concluding that the probative evidence of the defendant’s prior crimes toward ex-girlfriends to show common scheme to control through violence and intimidation outweighed prejudicial effect to the defendant from its admission
- holding where trial court did not have benefit of Holmes decision and thus did not engage in analysis regarding whether ineffectiveness claims fell into either exception to general rule of deferral, appellant should have opportunity to pursue all ineffectiveness claims, not me…
- holding that even if error occurred in admitting evidence of telephone conversation, it was harmless because it was “cumulative of other properly-introduced evidence with substantially similar content”

## Opinion text

DISSENTING OPINION
Justice SAYLOR.
The majority posits that the panoply of other-bad-acts evidence presented by the Commonwealth was not introduced to establish Appellant’s propensity for violence, but rather, was offered to establish his identity as the killer. See Majority Opinion, at 844. However, as the decisional law gravitates further and further away from the centering ground of signature crimes, see 1 McCormiok, Evidence § 190 (4th ed. 1992), the identity/propensity distinction devolves to a matter of semantics. It may well be, as the majority appears to suggest, that Appellant’s past violent conduct directed toward women was a key aspect of the prosecution. See Majority Opinion, at 844-45. Nevertheless, upon review of this record, I am unable to sup *861 port the majority’s conclusion that the Commonwealth’s case against Appellant was not, in material part, character and propensity based.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4968578. Public record. Not legal advice.