In Commonwealth v. Frame, the Pennsylvania Superior Court reaffirmed its allegiance to Commonwealth v. Reid, wherein the Supreme Court held that the United States Supreme Court’s holding in Williams v. Pennsylvania did not apply retroactively. Williams had provided some relief for capital litigants for whom Justice Castille — formerly known as District Attorney Castille — had impacted their cases in both of those roles. Mr. Frame’s case presents a good cautionary tale. While on trial for minor offenses, Mr. Frame’s “youthful indiscretion caused him to openly ridicule and embarrass ADA Connelly after the trial court had admonished the prosecution during that particular trial.” Fast forward 31 years and then-ADA Connelly was Judge Connelly, who presided over Mr. Frame’s first-degree murder trial. Now, Mr. Frame is serving life without parole. I hope none of my “youthful indiscretions” come back to bite me as Mr. Frame’s did.
