Com. v. Bradfield

Citations: 508 A.2d 568; 352 Pa. Super. 466; 1986 Pa. Super. LEXIS 10525

Court: Supreme Court of Pennsylvania; May 2, 1986; Pennsylvania; State Supreme Court

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William S. Bradfield was convicted of the deliberate murder of Susan Reinert and her two children, Karen and Michael, receiving three consecutive life sentences. His appeal argued against jurisdiction, claiming no evidence showed a murder occurred in Dauphin County, where he was tried. Jurisdiction requires that an overt act related to the crime occurs within the county. The court affirmed that the Commonwealth could establish jurisdiction through circumstantial evidence, as the Crimes Code allows for jurisdiction based on the location of the victim's body or the act causing death. The body of Susan Reinert was discovered in Dauphin County, which supported the presumption that her death occurred there, despite her last known location being Delaware County. Additionally, evidence indicated a conspiracy between Bradfield and another individual to murder Reinert for insurance proceeds, which also implicated the deaths of her children. Thus, the court upheld that jurisdiction in Dauphin County was proper for all related murders due to the conspiracy.

The proceedings were appropriately held in Dauphin County under the venue provisions of 42 Pa.C.S. 4551(d), allowing the supervising judge to select a county for trial when a multicounty investigating grand jury returns a presentment. This provision permits the consolidation of offenses in a single trial as long as at least one offense occurred in the chosen county, regardless of whether all crimes were committed there. The General Assembly retains the authority to define court jurisdiction, which includes the ability to convene multicounty grand juries to investigate extensive criminal activities or public corruption. The intent of the legislature was to avoid separate trials in multiple counties for interconnected crimes, supporting the idea that the supervising judge can designate a single trial location.

In this case, Susan Reinert’s body was found in Dauphin County, justifying the trial there for all murders related to a scheme to collect life insurance. The appellant contended that the grand jury lacked authority to issue a presentment because the alleged crimes did not meet the legislative definitions of organized crime or public corruption. However, this argument was deemed unsubstantiated. Organized crime encompasses ongoing criminal conspiracies aimed at significant economic gain through fraudulent practices, and evidence indicated that the appellant's actions constituted such a conspiracy. The conspiracy did not conclude with the murders; instead, these acts were part of a broader scheme to obtain insurance proceeds. The grand jury is permitted to address completed criminal activities discovered during the investigation of ongoing crimes, making it unreasonable to argue otherwise. The grand jury acted within its authority when addressing the improper sale of state property related to the investigation of Penn-DOT corruption, as the evidence arose during that inquiry.

Paul Tressler, a county prosecutor, expressed his emotional commitment to securing a conviction during grand jury proceedings, emphasizing the importance of presenting only admissible evidence. He acknowledged the gravity of the case involving the Reinert children, highlighting their lost opportunities for a normal childhood. The appellant argued that Tressler's comments were inflammatory and prejudicial, necessitating the quashing of the presentments against him. The court retains discretion to grant or deny such motions, only reversing a decision in cases of clear abuse or substantial harm to the defendant's rights. The court found Tressler's remarks were not egregious given the overall evidence, which supported the presentment. Previous rulings indicated that inflammatory remarks by officials do not invalidate indictments if there is sufficient evidence. The appellant's assertion that the prosecution for murder and conspiracy should be dismissed under 18 Pa.C.S. § 110, due to a prior conviction for theft by deception, was also addressed. This section bars prosecutions for offenses arising from the same criminal episode if known to the prosecutor at the first trial. However, the court did not find grounds to dismiss the presentment based on these arguments.

In Commonwealth v. Hude, the Pennsylvania Supreme Court established criteria for determining what constitutes a single criminal episode, emphasizing both the temporal sequence and the logical relationship between acts. The court referenced a law review article suggesting that statutory offenses are logically related if there is substantial duplication of factual or legal issues; mere additional issues do not suffice for separate criminal episodes. Temporal proximity is relevant but not exclusive, as offenses can be part of a single episode even if not immediately sequential.

In this case, the appellant was previously convicted of theft by deception in 1981 for misappropriating $25,000 from Susan Reinert between January and April 1979. The subsequent homicides, occurring in June 1979, were committed to obtain benefits from Reinert’s life insurance policy. The court found that the theft and homicides were neither temporally nor logically related; they were separate acts with different motivations and were not necessary steps in a unified criminal objective. The appellant’s ability to gain Reinert's trust was the only connection, but this did not establish an episodic link. Additionally, the court noted that at the time of the theft charge, the Commonwealth did not have sufficient evidence to charge the appellant with homicides until after the theft conviction. Therefore, the trial court correctly denied the motion to dismiss the charges on the basis of them arising from a single criminal episode.

The Commonwealth had sufficient circumstantial evidence to potentially support a guilty verdict for homicide but was not obligated to charge the appellant with those offenses if it doubted the evidence's ability to secure a conviction. Additionally, the Commonwealth was not required to delay charging the appellant with theft to avoid the statute of limitations expiring. The appellant claimed the trial court erred by denying his request for a change of venue due to extensive and prejudicial pre-trial publicity regarding the deaths of Susan Reinert and her children. The court's decision on a change of venue is discretionary and will not be overturned absent an abuse of discretion. To succeed in such claims, a defendant must typically show that pre-trial publicity caused actual jury prejudice. However, if the publicity is sufficiently pervasive and inflammatory, the burden may shift. The trial court must evaluate the publicity's content, especially concerning the accused's criminal record, confessions, or guilt implications. If the court finds significant exposure among prospective jurors to damaging publicity, denying a change of venue may constitute an abuse of discretion unless enough time has elapsed for any initial prejudice to dissipate. In this case, while much of the notoriety surrounding Susan Reinert's death occurred in 1979 and 1981, renewed media interest in April 1983, close to the trial, focused on the appellant's theft conviction and an alleged admission related to the murders.

Evidence was presented at trial regarding media references to the appellant's diary, which expressed a desire to kill Susan Reinert for insurance money, and statements made to inmate Arnold Winder about the appellant's involvement in the murders and intentions to kill witnesses. However, these latter statements were not admitted as evidence. The focus was on whether prospective jurors were significantly influenced by the prejudicial media coverage. Articles published in major Harrisburg newspapers indicated substantial circulation, with The Patriot at 25%, The Evening News at 34%, and the Sunday Patriot at 62% of the voting population in Dauphin County. Between the appellant's arrest and the trial commencement, 44 articles were published, though not all contained prejudicial material. 

The acceptable legal standard evaluates whether jurors formed fixed opinions on guilt or innocence due to pre-trial publicity. While acknowledging that jurors might have some preconceived notions, it is crucial they can set these aside and base their verdict solely on trial evidence. Out of 92 jurors examined, only 8 had formed fixed opinions about the appellant's guilt, and those selected affirmed their impartiality. Therefore, it was concluded there was no actual juror prejudice from the pre-trial publicity, which was not deemed pervasive enough to impede a fair trial. This finding aligns with precedents set in Commonwealth v. Romeri, where a similar situation concluded that less than 8% of jurors with fixed opinions did not indicate pervasive prejudicial publicity.

A change of venue is mandated when a significant majority of prospective jurors harbor fixed opinions on a defendant's guilt, as demonstrated in previous cases where 53% or more of jurors were excused due to prejudgment. In contrast, less than 9% of jurors in the current case had formed fixed opinions, indicating that pre-trial publicity did not predispose the community against the appellant. The Commonwealth's theory did not assert that the appellant physically committed the murders but rather that he was criminally liable as an accomplice or co-conspirator, making the conspiracy element critical for the case. The trial court's decision to allow the charges of conspiracy and homicide to be tried together was not an abuse of discretion.

The court permitted testimony regarding statements made by the victim, Susan Reinert, about her intentions to marry the appellant and provide him with her deceased mother's engagement ring and $25,000 for investment. Although these statements fell under hearsay, they were admissible to demonstrate Reinert's state of mind. The appellant, while acknowledging this hearsay exception, claimed that admitting these statements violated his constitutional right to confront his accuser. However, the right of confrontation is not absolute, and the admissibility of hearsay depends on its purpose and the risks of admission. Previous rulings affirmed that similar statements did not infringe upon confrontation rights when related to state of mind, especially when the declarant is unavailable.

In this instance, the contested evidence was not central to the Commonwealth's case and merely illustrated the trust Reinert had in the appellant, which was corroborated by other circumstantial evidence. Consequently, the court concluded that the admission of this evidence was not prejudicial and did not warrant a new trial.

In Commonwealth v. Maxwell, the Pennsylvania Supreme Court addressed the Commonwealth's right to question jurors about their views on the death penalty. The Court found that merely inquiring about jurors' stances or excluding those opposed to the death penalty does not inherently lead to a biased jury. The appellant's claims of unfair trial due to juror exclusion were rejected, as he could not demonstrate any prejudice from the exclusion of jurors who opposed capital punishment. The Court also dismissed the argument that the Attorney General should have articulated the reasons for each peremptory challenge, asserting that such challenges are inherently subjective and immune to scrutiny.

Furthermore, the appellant's assertion of bystander misconduct—specifically a remark made by a citizen during jury transport—was unsupported by record evidence, thus failing to establish any impact on the jury's verdict. The court emphasized that decisions must be based on the factual record, and speculation or unsubstantiated claims cannot warrant a new trial. 

The trial's integrity was reinforced by its length and the jury's adherence to instructions to base their verdict solely on trial evidence. The Court reviewed other points raised by the appellant, including the denial of a continuance, limitations on voir dire, exclusion of certain evidence, and issues related to jury qualification for the death penalty. All these arguments had been thoroughly considered by the trial court without finding merit. Lastly, the appellant's claim of ineffective assistance of counsel due to failure to object to jury instructions on accomplice liability was also addressed without leading to a favorable outcome for the appellant.

Appellant is represented by the same counsel from the trial, and since counsel's ineffectiveness is not evident from the record, prior case law necessitates remanding the case for new counsel to be appointed. The current judgment of sentence is vacated, and remand is ordered to address the appellant's claim of ineffective trial counsel. If the trial court finds that counsel's assistance was constitutionally effective, the sentence may be reinstated. Conversely, if counsel is found to have been ineffective, a new trial will be granted. The court does not retain jurisdiction during this process. Judge Olszewski concurs, emphasizing the necessity of a remand based on controlling precedents, while clarifying that the court is not making judgments about counsel's effectiveness at this stage, but rather addressing potential deliberate errors.

The Philadelphia County Court of Common Pleas has implemented a rule addressing situations where attorneys acknowledge their incompetence in filing appeals. Additionally, the Chief Justice of the Pennsylvania Supreme Court has suggested that the Supreme Court Criminal Rules Committee should consider establishing a statewide rule regarding attorney incompetency to facilitate new trials. 

In discussions regarding venue and jurisdiction, there is confusion, yet courts have consistently determined that the location of a crime dictates which court has the authority to try the case. Even if the murder of Susan Reinert had occurred elsewhere, the subsequent placement of her body in Dauphin County was integral to the conspiracy and established jurisdiction for the Dauphin County courts.

The appellant was initially convicted of conspiracy, but the trial court later granted a motion to arrest judgment due to the expiration of the statute of limitations for those charges. At the commencement of the trial, it was understood that the statute of limitations for conspiracy matched that of the most serious related crime, in this case, murder. However, after the trial, the Supreme Court reversed prior case law, establishing a two-year statute of limitations for conspiracy.

Regarding evidence, the Commonwealth's Bill of Particulars indicated uncertainty about the specific actions of the appellant in connection with the murders. The appellant contended that this ambiguity would preclude the introduction of evidence supporting an accomplice theory of liability. The court disagreed, stating that the Commonwealth's information was consistent with a co-conspirator theory of murder liability.

Relevant constitutional references include the Sixth Amendment of the U.S. Constitution and Article 1, Section 9 of the Pennsylvania Constitution.