Commonwealth v. Chapman, 682 CAP
| Decision Date | 29 March 2016 |
| Docket Number | No. 682 CAP,682 CAP |
| Citation | 136 A.3d 126 |
| Parties | COMMONWEALTH of Pennsylvania, Appellee v. Laquanta CHAPMAN, Appellant. |
| Court | Pennsylvania Supreme Court |
J. Michael Farrell, Esq., P.J. Redmond, Esq., Chester County Public Defender's Office, for Laquanta Chapman.
Patrick Carmody, Esq., Nicholas J. Casenta Jr., Esq., Chester County District Attorney's Office, Amy Zapp, Harrisburg, for Commonwealth of Pennsylvania
OPINION
.
This is a capital direct appeal.
On October 30, 2008, Appellant shot and killed his sixteen-year-old neighbor, Aaron Turner, in the basement of Appellant's residence. Subsequently, with the assistance of his younger cousin, Bryan Bird, Appellant dismembered the victim's body and disposed of the remains in the trash.
Weeks later, law enforcement officers investigating the sale of illicit drugs from Appellant's premises obtained a warrant to search them for evidence of drug activity. In the course of the ensuing search, police discovered an abundance of residual, physical evidence from the killing and dismemberment. Appellant was arrested and charged with murder and other crimes, and the Commonwealth tendered notice of an intention to pursue the death penalty.
At Appellant's trial before a jury, the defense admitted that Appellant had perpetrated most of the crimes with which he was charged (other than murder). See, e.g. , N.T., Nov. 1, 2012, at 52–53; N.T., Nov. 8, 2012, at 98. In line with these concessions, the defense acknowledged that the victim had been killed in the basement of Appellant's residence, see, e.g. , N.T., Nov. 1, 2012, at 149, and that Appellant “was involved in cleaning up the crime scene.” N.T., Nov. 8, 2012, at 98. The defense contended, however, that there was reasonable doubt concerning the identity of the shooter and attempted to shift the blame to Bryan Bird.
The jury nonetheless convicted Appellant of first-degree murder and other offenses and returned a death verdict in a separate penalty proceeding. Post-sentence motions were filed and denied, and this direct appeal followed.
Although Appellant does not challenge the sufficiency of the evidence supporting his first-degree murder conviction, this Court automatically undertakes such review in capital direct appeals.
In the present case, the only element of first-degree murder ever in question pertained to identity, since the deliberate, malicious killing and subsequent dismemberment of Aaron Turner were amply established by physical evidence.1 The Commonwealth presented testimony from Bryan Bird that he was an eyewitness to Appellant's perpetration of the killing, see, e.g., N.T., Nov. 5, 2012, at 36, and an inmate testified that, while in jail awaiting trial, Appellant confessed to having killed the victim. See N.T., Nov. 7, 2012, at 100–107. Such evidence, in and of itself, was plainly sufficient to support the jury's determination. Moreover, the Commonwealth presented a wealth of corroborating circumstantial evidence, including Appellant's attempts to destroy evidence and lies to police during their investigation,2 evidencing his consciousness of his guilt.
In his first guilt-phase claim for relief, Appellant asserts that the common pleas court erred when it denied a pretrial motion seeking to suppress evidence taken from his residence. Appellant styles this claim as follows: “Search of House Impermissible as Beyond the Breadth of a Search Warrant Describing Criminal Conduct in a Detached Garage. ” Brief for Appellant at 18 (emphasis adjusted). Consistent with this framing, Appellant's argument assumes that the affidavit of probable cause supporting the initial warrant described criminal conduct only in the garage. See, e.g., id. (); id. at 19 (). While indicating that it is permissible to extend an authorized search of a residence to the curtilage, Appellant contends that such an approach should not operate in the reverse, particularly given the decisions of this Court allocating to residences the strongest protection from unreasonable searches. See, e.g., Commonwealth v. Brion, 539 Pa. 256, 257, 652 A.2d 287, 287 (1994)
(). Appellant also suggests that a particular description of the place to be searched, in terms of the residence, was lacking in the relevant search warrant. See Brief for Appellant at 19.
A primary flaw in this argument is that it is materially misleading. Initially, the search warrant under review expressly identified the premises to be searched as follows:
Application for Search Warrant and Authorization at 1 (emphasis added). Thus, the residence was very plainly encompassed within the warrant.
Moreover, although Appellant is correct that the affidavit of probable cause describes controlled drug purchases occurring in the garage, the affiants also specifically sought permission to search the residence based, inter alia, upon attestations that: the affiants had particularized knowledge and experience with drug trafficking; “it is common for larger-scale narcotic traffickers to secrete contraband, proceeds of narcotics sales, and records of drug transactions in secure locations within their residences”; “narcotics traffickers commonly have in their possession, that is on their person, at their residence and/or their businesses, firearms”; and “three individual sources ... relayed that over the past month the foot traffic and suspected drug activity which had been taking place from the garage ... has moved to the rear door of the residence which is where all of the activity is now taking place.” Id. at 3, 5, 8 (). Upon consideration of this and other information within the four corners of the affidavit of probable cause, the attesting officers indicated:
[B]ased on your affiants' experience and training, and the facts described herein, it is you affiants' opinion that there is ongoing drug trafficking taking place inside the residence listed above. Your Affiants believe that there is a fair likelihood that [the] aforementioned residence will contain those items listed in the section titled Items to be searched for and seized within this document.
Id. at 8 (emphasis added).
Commonwealth v. Luv, 557 Pa. 570, 576, 735 A.2d 87, 90 (1999) (). Appellant's presentation, however, does not implicate an examination of this line of precedent, since he offers no argumentation assailing the quality or veracity of the information collected by the affiants.
In summary, Appellant's position that the search warrant was directed only to the garage and described only criminal conduct in such location is facially meritless.
Next, Appellant complains that his constitutionally protected refusal to voluntarily surrender a DNA sample to investigators was wrongfully used against him at trial.
By way of background, in his examination of a detective at trial, the prosecutor elicited a statement that Bryan Bird and another suspect had voluntarily provided DNA samples to police but that Appellant had refused to do so. See N.T., Nov. 5, 2012, at 123. Appellant's counsel advanced a general objection, and the trial court, acting sua sponte, cautioned the jurors as follows:
Despite this instruction, the defense then moved for a mistrial on the basis that the refusal was “clearly an assertion of the right to silence.” Id. at 124. The court denied this motion but, anticipating that the prosecution intended to display to the jury a videotape of the police interview with Appellant, directed the prosecutor to redact references to Appellant's refusal to furnish a DNA sample. See id. at 125. Although the tape was redacted to remove some references to such refusal, apparently one was missed, see id. at 135–36, which proceeded as follows:
The defense again moved for a mistrial, see id. at 135, and the trial court denied that...
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