High Court Upholds Pa. Sniper's Death Sentence
The Pennsylvania Supreme Court has ruled that Eric Frein's conviction and death sentence for shooting and killing a State Trooper and injuring another was proper, despite the admission of some questionable victim impact evidence at trial.
April 30, 2019 at 02:38 PM
5 minute read
The Pennsylvania Supreme Court has ruled that Eric Frein's conviction and death sentence for shooting and killing a State Trooper and injuring another was proper, despite the admission of some questionable victim impact evidence at trial.
Frein ambushed the Blooming Grove state police barracks in September 2014, fatally shooting Cpl. Bryon K. Dickson II and severely injuring Trooper Alex Douglass. The shooting grabbed national attention as Frein led law enforcement officials on a nearly 50-day manhunt. The 35-year-old was sentenced to death after a jury convicted him of first-degree murder; first-degree criminal homicide of a law enforcement officer; criminal attempt to commit first-degree murder and criminal homicide of a law enforcement officer; assault of a law enforcement officer in the first degree; terrorism; weapons of mass destruction; discharge of a firearm into an occupied structure; and possessing instruments of crime.
The high court unanimously upheld Frein's convictions and ruled 6-1 to affirm his death sentence.
The justices disagreed on whether the admission of certain victim impact evidence—including the testimony of Dickson's widow about the couple's fertility struggles, testimony from Dickson's colleagues about his skill and bravery as a trooper, and dozens of photographs showing Dickson with his family—prejudiced Frein and entitled him to a new penalty phase.
The majority, led by Justice Debra Todd, said the victim impact evidence “was extensive, arguably unnecessarily so,” and at times did not even qualify as victim impact evidence at all.
“Nevertheless, we are constrained to agree with the commonwealth that, because the jury found several aggravating circumstances, but no mitigating factors, appellant has failed to establish that he was prejudiced by the admission of the above-described testimony,” Todd said in the majority opinion, joined by Chief Justice Thomas Saylor and Justices Max Baer, Kevin Dougherty and Sallie Updyke Mundy.
The majority found that the trial court's jury instruction on how to weigh victim impact evidence was proper.
“A jury is presumed to follow the trial court's instructions on the law,” Todd said. “Herein, the trial judge instructed the jury that it could not consider the victim impact testimony unless it found at least one aggravating circumstance and at least one mitigating circumstance. The jury did not find any mitigating circumstances, and, therefore, it must be presumed that the jury did not consider the commonwealth's victim impact testimony in rendering its verdict. As such, we hold that appellant has failed to establish a basis for relief.”
Justice Christine Donohue wrote a separate concurring opinion joining in the result and noting her belief that Frein was not entitled to a new penalty phase because he failed to object that the evidence admitted did not meet the statutory definition of victim impact evidence.
“If the available evidentiary objections had been asserted and the trial court had granted some or most of them, we would have a very different, and considerably smaller, record before us now—which may or may not have supported Frein's due process claim,” Donohue said. “Alternatively, if the trial court had denied the statutory objections, Frein could have challenged these evidentiary rulings on appeal to this court as grounds for a new penalty phase trial, while simultaneously presenting his due process constitutional arguments.”
But Justice David Wecht filed a concurring and dissenting opinion, arguing that Frein's failure to lodge a statutory objection at trial was irrelevant and that the defendant was entitled to a new penalty phase because “the victim impact evidence was of such a quantity and character that, even considering the trial court's instruction to the jury, the resultant prejudice rendered the proceeding fundamentally unfair.”
“At minimum, there existed a strong likelihood that the victim impact evidence was so extensive, and so emotionally charged, that it prejudiced the jury to the degree that the jurors were incapable fairly of assessing the existence of aggravating and mitigating factors,” Wecht said. “For this reason, I am compelled to disagree with the majority's holding that the general presumption that juries follow a trial court's instructions sufficed to ensure that the jury here was not influenced by this overwhelming body of emotional evidence.”
The court unanimously made quick work of another issue that consumed much of the oral argument in the case last March: whether detectives' questioning of Frein in a videotaped interview after his arrest violated his Miranda rights.
The justices said the trial court clearly committed an error by allowing the videotaped interview into evidence because detectives had persisted in questioning Frein even after the defendant had invoked his right to remain silent. However, the justices said that error was harmless.
“In the instant case, we have no hesitation in concluding that the trial court's error in refusing to suppress the statements made by appellant in his post-arrest videotaped interview was harmless because the properly admitted and uncontradicted evidence of guilt was so overwhelming, and the prejudicial effect of the admission of appellant's videotaped interview so insignificant by comparison, that its admission could not have contributed to the verdict,” Todd said.
Michael Weinstein of Weinstein, Zimmerman & Ohliger in Milford declined to comment on the decision.
Pike County District Attorney Raymond Tonkin could not be reached for comment.
(Copies of the 75-page opinion in Commonwealth v. Frein, PICS No. 19-0530, are available at http://at.law.com/PICS.)
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