finding that Appellant’s signature on the government form was appropriately used as a handwriting exemplar to compare to the signatures on the checks drawn on Goodman’s account, and that testimony concerning the use of the name “Anna” King when checking into a motel near the prison was probative of Appellant’s knowledge that Martin would be improperly absent from prison and of her desire to facilitate his escape
How later courts described this case
- finding that Appellant’s signature on the government form was appropriately used as a handwriting exemplar to compare to the signatures on the checks drawn on Goodman’s account, and that testimony concerning the use of the name “Anna” King when checking into a motel near the prison was probative of Appellant’s knowledge that Martin would be improperly absent from prison and of her desire to facilitate his escape
- explaining that there “was no need for an expert to testify to the fear that [the victim] felt in his confrontation with [the defendants]—the fact that a human being would experience fear [during a violent episode] is so basic that expert opinion is unnecessary to assist the jury”
- holding that the trial court did not abuse its discretion in admitting photograph depicting the manner in which the victim was tied and which showed graphic signs of the body’s decomposition, including blackening of hands and secretion of bodily fluids
- pointing out that a Simmons instruction was not required when "the issue of future dangerousness was not before the jury. At no time during either phase of trial did the prosecutor argue or suggest that the death penalty should be imposed because Appellants could potentially hurt someone else. . . ."
Written by the judges who cited it.
The opinion
NEWMAN, Justice,
concurring.
I join the majority, and write separately only to reiterate the position I expressed in Commonwealth v. Chandler, 554 Pa. 401 , 721 A.2d 1040 , regarding the “life means life” issue. As I stated in Chandler :
[I]n cases where Simmons would require a “life means life” instruction, I agree with Chief Justice Flaherty that the court should instruct the jury that the defendant’s sentence could be commuted. Where future dangerousness is at issue, the impossibility of parole and the possibility of *378 commutation are equally relevant, so the court should inform the jury of both contingencies.
In this case, I agree with the majority that future dangerousness was not at issue. Accordingly, I agree that the trial court properly declined to give a “life means life” instruction.