Commonwealth v. Talley

In a sixty-five page opinion, the Pennsylvania Supreme Court clarified the prosecution’s burden when the Commonwealth seeks to deprive the accused of their right to bail. Also, the Court ruled that the defendant’s text messages to the victim were admissible at the his trial. The defendant was arrested and charged with aggravated assault, stalking, harassment and related offenses. After he was in jail for 180, the defendant filed a Pa.R.Crim.P. 600 motion. The trial court denied the defendant’s motion and granted the Commonwealth’s motion to revoke bail. At the trial, the defendant objected to the admission of the victim’s screenshots of the defendant’s text messages to her. The trial court overruled the objection and convicted the defendant. On appeal, the defendant argued that the trial court erred when it denied his 600 Motion, and that the best evidence rule should have precluded the admission of the screenshots. The Superior Court affirmed. The Supreme Court agreed that the trial court erred in denying the 600 Motion. But a new trial was not warranted. The Supreme Court then affirmed the trial court’s admission of the screenshots.   First, the Supreme Court ruled that “when the Commonwealth seeks to deny bail due to the alleged safety risk the accused poses to any person and the community, those qualitative standards demand that the Commonwealth demonstrates that it is substantially more likely than not that (1) the accused will harm someone if he is released and that (2) there is no condition of bail within the court’s power that reasonably can prevent the defendant from inflicting that harm. While we decline to provide an exhaustive list of circumstances that would suffice to deny bail in a given case based upon prospective harms, a bail court should consider the defendant’s character, relevant behavioral history, or past patterns of conduct; the gravity of the charged offense; the conditions of bail reasonably available to the court; and any evidence that tends to show that those conditions would be inadequate to ensure the protection of any person or the community.” Next, the Court held that the screenshots of the defendant’s text messages were subject to the best evidence rule because they “were closely related to a controlling issue because their contents were necessary to prove the elements of” two crimes charged. Under Rule 1001, because the screenshots were not created in order to have the same intended effect as the original text messages, the screenshots constituted duplicates, not counterparts. And the screenshots were admissible as duplicates because they met the criteria in Pa.R.Evid. 1001(e) and 1003.

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