HomeMy WebLinkAboutCP-21-CR-0000088-2009
COMMONWEALTH : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
V. :
:
VINCENT LEE FLEMISTER : CP-21-CR-0088-2009
IN RE: OPINION PURSUANT TO PENNSYLVANIA
RULE OF APPELLATE PROCEDURE 1925
Masland, J., November 22, 2010:--
In March 2010, a jury convicted Vincent Lee Flemister (Defendant) of two
counts of robbery, criminal conspiracy to robbery, aggravated assault, burglary,
criminal attempt to criminal homicide, and criminal trespass. He now appeals his
convictions arguing, first, that the verdicts were against the weight of the
evidence and second, that the Commonwealth failed to disclose an agreement to
sentence his accomplice leniently in exchange for testimony. For the following
reasons, these contentions lack merit and the Superior Court should affirm the
convictions.
I. Weight of the Evidence
It is well-settled that in considering a challenge to the sufficiency of the
evidence, the reviewing court views the evidence in the light most favorable to
the Commonwealth as the verdict winner and draws all reasonable inferences in
the Commonwealths favor. Commonwealth v. O'Bryon, 820 A.2d 1287, 1290
(Pa. Super. 2003). Further, as the trier of fact, the jury is the ultimate arbiter of
the weight of the evidence and credibility of witnesses. As such, they are free to
believe all, part, or none of the evidence. Commonwealth v. Griscavage, 517
A.2d 1256, 1257 (Pa. 1986).
CP-21-CR-0088-2009
A. Victim Testimony
Defendant first attacks the testimony of the two victims who identified the
Defendant as their assailant. He argues the victims' testimony was unreliable
because they “had a limited opportunity to view their assailant because [he] wore
a mask and had a hood pulled down over his head.” Concise Statement of the
Errors Complained of on Appeal (Concise Statement) at ¶1(a). He also
contends, “[t]here was no lineup or photo array and the Courtroom identification
was very suggestive.” Id. Defendant's argument amounts to no more than an
attack on the victims' credibility and must therefore be rejected.
Both victims identified Defendant as their assailant in open court.
Defendant's counsel cross-examined both victims extensively regarding their
ability to identify the masked attacker. Notwithstanding Defendant's attacks on
the victims' credibility, the jury found the victims' identification of Defendant
credible and that determination should not be disturbed.
B. Accomplice
Defendant next attacks the credibility of his accomplice. He argues the
accomplice, Andres Rodriguez, was “an admitted accomplice and therefore a
polluted source of information.” Concise Statement at ¶1(b). Again, Defendant's
argument does no more than attack the jury's credibility determinations and must
be rejected.
It is well established that in any case where an accomplice testifies
against a defendant, the court should tell the jury that the accomplice is a corrupt
and polluted source whose testimony should be viewed with great caution.
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Commonwealth v. Chmiel, 639 A.2d 9, 13 (Pa. 1994).
At trial, Rodriguez testified extensively regarding the planning, execution,
and aftermath of Defendant's crimes. He also testified to his own role as
Defendant's accomplice. Further, during jury instructions, the court gave a
corrupt source charge warning the jury of the inherent unreliability of an
accomplice's testimony. Despite all this, the jury found Rodriguez credible and
convicted Defendant of all charges against him. Again, witness credibility is
exclusively the jury's prerogative. Here, the jury was well aware of Rodriguez's
status as a polluted source of information yet still found him credible. A reviewing
court should not disturb this determination.
C. Conclusion – Weight of the Evidence
The guilty verdicts against Defendant were amply supported by the
evidence. Notwithstanding extensive corroborating circumstantial evidence not
challenged here, both victims identified Defendant as their attacker and his
accomplice testified to the planning, execution, and aftermath of the crimes. In
fact, Rodriguez's testimony alone could constitute sufficient evidence to support
the guilty verdicts. Commonwealth v. Mikell, 729 A.2d 566, 570 (Pa. 1999) (“[A] a
verdict may be predicated upon the uncorroborated testimony of an
accomplice.”). For these reasons, the verdicts are supported by sufficient
evidence and should be affirmed.
II. Undisclosed Agreement Between Commonwealth and Rodriguez
Defendant next asserts, “that the Commonwealth and Andres Rodriguez
failed to disclose to the Defense and to the jury in testimony the benefit that
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Andres Rodriguez would receive for his testimony in this case.” Concise
Statement at ¶2. Because Defendant offers little more than conjecture that such
an agreement exists, this argument must be rejected.
At trial, Rodriguez testified that there were no deals for his testimony other
than he would receive consideration for his cooperation. After Defendant's
convictions, Rodriguez pled guilty to a charge of criminal conspiracy and was
initially sentenced to 391 days (time served) to seven years incarceration with
immediate parole. His sentence was subsequently amended to time served to
five years less a day, and then amended to a sentence of 11 ½ months to 23
months in county prison followed by a consecutive probationary sentence of 36
months. The Commonwealth did not oppose these sentencing modifications.
On these facts, Defendant imagines some agreement exists beyond the mere
consideration mentioned at trial. He is incorrect.
The Commonwealth is obligated to disclose exculpatory evidence material
to the guilt or punishment of an accused. Brady v. Maryland, 737 U.S. 83 (1963).
Exculpatory evidence includes impeachment evidence material to the case
against the accused. Commonwealth v. Burkhardt, 833 A.2d 233, 241 (Pa.
Super. 2003). An agreement for leniency in exchange for testimony is relevant to
a witness's credibility. Id. Thus, the Commonwealth is obligated to disclose the
existence of such an agreement with a witness where that witness's testimony is
material to the Defendant's guilt or innocence. Commonwealth v. Strong, 761
A.2d 1167, 1171 (Pa. 2000).
Here we need not address the materiality of Rodriguez's testimony
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because the record contains nothing to indicate the existence of an undisclosed
agreement. What the record does indicate is that Rodriguez testified he would
receive consideration for his cooperation with the investigation and prosecution
of Defendant. The sentence he received and its subsequent modifications reflect
just that, consideration for his cooperation, nothing more. Defendant offers only
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speculation to show the existence of an undisclosed agreement. Thus, his
contention lacks merit. Commonwealth v. Morales, 701 A.2d 516, 523 (Pa.
1997).
III. Conclusion
In sum, the guilty verdicts against Defendant are amply supported by the
evidence. Both victims and his accomplice all positively identified Defendant as
the assailant. Notwithstanding the corroborative circumstantial evidence not
challenged here, the eyewitness and accomplice testimony constitute sufficient
evidence to support all the guilty verdicts duly rendered by the jury. Further,
Defendant's allegation of an undisclosed leniency agreement lacks merit. His
contention lacks any support in the record, is purely conjecture, and must be
rejected. For all these reasons, the Superior Court should affirm the guilty
verdicts in all respects.
The multiple sentences are not an indication of court complicity in some
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nefarious agreement. To the contrary, they are indication of a new judge’s
attempts to get the sentencing right. Once I determined that time served was
appropriate it was just a matter of making sure that the sentence permitted the
county and not the state to provide the supervision. Therefore, with respect to
awkward sentencing behaviors, I plead guilty; however, with respect to
“suggestive circumstances,” both the record and I should be found not guilty.
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By the Court,
Albert H. Masland, J.
Matthew P. Smith, Esquire
Assistant District Attorney
Taylor P. Andrews, Esquire
For Defendant
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