stating that no Simmons instruction was required because "[t]he aggravating circumstance of appellant's prior record for violent felonies addressed only appellant's past conduct, not his future dangerousness"
How later courts described this case
- stating that no Simmons instruction was required because "[t]he aggravating circumstance of appellant's prior record for violent felonies addressed only appellant's past conduct, not his future dangerousness"
- holding that the aggravating circumstance of a significant history of prior violent felony convictions involves only the defendant's past conduct, not his future dangerousness.
- holding that evidence regarding a defendant's past violent convictions or conduct does not implicate the issue of his or her future dangerousness
- reflecting a similar instruction centered on the requirement that "the defendant committed a killing while in the perpetration of a felony"
Written by the judges who cited it.
The opinion
ZAPPALA, Justice,
concurring.
I concur in the result for the reasons set forth in my concurring opinion in Commonwealth v. Clark, 551 Pa. 258 , 710 A.2d 31 (Pa. 1998).