Pennsylvania v. Keaton

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Appellant Alexander Keaton appealed the denial of his application for post-conviction relief; the Commonwealth cross-appealed the grant of a new penalty phase based on trial counsel's ineffectiveness for failing to present mitigating mental health evidence. In 1992, Appellant was charged with rape and related offenses stemming from the sexual assault of Nadine S. One month later, the body of Appellant's ex-girlfriend was found. After waiving his rights, Appellant gave a written statement incriminating himself in the killing, and he was charged with murder. Appellant sexually assaulted two other women, making self-incriminating statements. The Commonwealth moved to consolidate the charges for all victims. Over defense objection, the trial court granted the motion. Prior to trial, Appellant moved to suppress his statements; the motion was denied, and Appellant was tried before a jury and found guilty of first degree murder, rape, and related offenses. At the penalty phase, the Commonwealth sought to prove several aggravating circumstances. The jury found no mitigating circumstances and one aggravating circumstance. Accordingly, Appellant was sentenced to death. Appellant timely filed a pro se PCRA petition and received appointed counsel, who filed an amended petition alleging all prior counsel's ineffectiveness for not raising numerous guilt and penalty phase issues. The PCRA court held a hearing on the sole issue of trial counsel's ineffectiveness for failing to investigate and present mitigating evidence at the penalty phase. The PCRA court rejected Appellant's guilt phase claims, and denied him a new trial. However, the court concluded trial counsel was ineffective for failing to develop and present mitigating evidence, and granted a new penalty hearing. The PCRA court's opinion did not address several of the issues in detail, it merely stated it found Appellant's claims of guilt phase error meritless and would not further discuss them; the only penalty phase issue the court addressed was trial counsel's ineffectiveness. Without conclusive findings regarding whether Appellant was mentally retarded, the Supreme Court could not address his "Atkins" claim; accordingly, the Court remanded for the PCRA court to consider that claim's merits. The PCRA court complied, and rejected Appellant's claim of mental retardation. On appeal of that decision, the Supreme Court determined that there was a factual question regarding whether Appellant invoked his Fifth Amendment right to counsel in 1992 when he made his self-incriminating statements. The Court remanded this issue to the PCRA court for determination of this issue and for the parties to address the applicability of the applicable case law if the court determined Appellant did invoke his right. As to Appellant's remaining guilt phase claims, the Supreme Court affirmed the PCRA court's denial of relief. View "Pennsylvania v. Keaton" on Justia Law