Pennsylvania v. Knight

This direct appeal to the Pennsylvania Supreme Court arose from the torture and murder of Jennifer Daugherty, a 30-year-old intellectually disabled woman. Over the course of two days, appellant and his five co-conspirators committed escalating acts of humiliation, abuse and torture upon Ms. Daugherty. The conspirators ultimately voted to kill Ms. Daugherty and murdered her in a vicious manner, including stabbing her in the chest, slashing her wrists and choking her. Appellant ultimately accepted responsibility by pleading guilty to first-degree murder, second-degree murder, conspiracy to commit murder, kidnapping, and conspiracy to commit kidnapping. He received the death penalty. After careful review of appellant’s fourteen issues, the Supreme Court was "constrained" to vacate the judgment of sentence and award a new penalty hearing on appellant’s thirteenth claim. Appellant had no prior felony or misdemeanor convictions; defense counsel proposed a stipulation stating that appellant had no prior criminal history. The prosecution did not object to the introduction of appellant's criminal history, but stated he would not stipulate to a mitigating circumstance. In his case in mitigation, defense counsel instead presented evidence of appellant’s lack of convictions through the testimony of a police detective, and the Commonwealth presented no contrary evidence. In closing, the prosecutor essentially admitted the fact to which he had refused a stipulation, but then argued appellant’s lack of criminal convictions was of little significance given other circumstances of the crime. Appellant argued on appeal of his death sentence that the jury was required to conclude a statutory mitigator was established. The Commonwealth noted that while it did not rebut appellant’s lack of criminal convictions, it argued to the jury “that the lack of criminal history was insignificant” given other circumstances, and “that mitigating factor should be given no weight by the jury and not consider it a mitigating factor.” The Supreme Court vacated the sentence and remanded for further proceedings: "[W]hen it is undisputed (or indisputable) the mitigator objectively exists, it would be wise for the prosecutor to stipulate and for the jury to be directed to find the mitigator, so the death penalty statute is followed. Failure to take such measures, for whatever reason, results in the situation here: the court below . . . accepted a verdict of death that included an arbitrary failure to honor a statutory mandate." View "Pennsylvania v. Knight" on Justia Law