Commonwealth v. DiStefano

The Pennsylvania Supreme Court held that the Superior Court misapplied the appellate court standard for reviewing trial court evidentiary rulings. The Commonwealth charged Appellant with homicide and aggravated assault. The MDJ concluded that the Commonwealth presented a prima facie case for both aggravated assault and homicide. The trial court ruled that the Commonwealth failed to present sufficient evidence to establish a prima facie case for homicide, but the aggravated assault charged remained. Appellant filed a motion in limine, asking the trial court to preclude the Commonwealth from presenting at his trial any evidence regarding the person’s death. The trial court granted the motion. The Commonwealth appealed, and the Superior Court reversed. The Supreme Court reversed and reinstated that trial court’s order. The Court held that that the Superior Court did not properly apply the abuse of discretion standard. The trial court correctly applied Rule 403. Further, the trial court’s view was not manifestly unreasonable. Lastly, there was nothing in the record or the trial court’s opinion that suggested that the court’s ruling was the result of partiality, prejudice, or ill-will.

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