HomeMy WebLinkAbout01-2114 CRIMINALCOMMONWEALTH
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS EDWARD QUACA
OTN: H264271-0
NO. 01-2114 CRIMINAL TERM
CHARGES: (1) ENDANGERING
WELFARE OF
CHILDREN
(2) RECKLESS
ENDANGERING
ANOTHER PERSON
(3)SIMPLE ASSAULT
IN RE: OPINION PURSUANT TO PA. R.A.P. 1925
OLER, J., March 26, 2002.
This criminal case arises out of a head trauma, preceded by rib fractures, suffered
by a seven-week-old infant. The head trauma occurred on March 27, 2000, and the rib
injuries occurred several weeks earlier. Allegedly, both sets of injuries were criminally
caused by Defendant, who was acting as caretaker for the child during the periods in
which they occurred. ~
At the conclusion of a jury trial at which the undersigned judge presided,
Defendant was found guilty of recklessly endangering another person,2 a misdemeanor of
the second degree, simple assault,3 a misdemeanor of the first degree, and endangering
the welfare of a child.4 The last offense was graded a felony of the third degree by virtue
of the jury's additional finding that there was a course of conduct on the part of
Defendant of endangering the welfare of the child.5
~ E.g., N.T. 7, Trial, September 6, 2001 (hereinafter N.T. ~.
2 Act of Dec. 6, 1972, P.L. 1482, No. 334, § 1, 18 Pa. C.S.A. § 2705 (West 1998 & Supp.
2001).
3 Act of Dec. 6, 1972, P.L. 1482, No. 334, § 1, as amended, 18 Pa. C.S.A. § 2701 (West
1998 & Supp. 2001).
4 Act of Dec. 6, 1972, P.L. 1482, No. 334, § 1, as amended, 18 Pa. C.S.A. § 4304 (West
1998 & Supp. 2001).
5 Order of Ct., Sept. 10, 2001.
Defendant has appealed to the Pennsylvania Superior Court from the judgment of
sentence.6 In a statement of matters complained of on appeal, Defendant has expressed
the grounds for the appeal as follows:
1. The Court erred in denying Defendant's Motion to Compel
the Commonwealth to provide Pa.R. Evid. 404(b) evidence to the Defendant
prior to trial.
2. The Court erred in finding Stephanie Foster competent to
testify without an in camera hearing to determine competency.
3. The evidence presented at trial was insufficient for a finding
of guilt on the charge of Endangering the Welfare of Children based upon a
course of conduct.
4. The Court erred in failing to grant a mistrial when Ms.
Foster[, the child's mother,] testified regarding her fear of Defendant.7
This opinion in support of the judgment of sentence is written pursuant to
Pennsylvania Rule of Appellate Procedure 1925(a).
STATEMENT OF FACTS
This case arises out of an incident in which Defendant allegedly inflicted head
trauma upon his seven-week-old son, Thomas Edward Quaca, Jr., on March 27, 2000,
following the infliction of rib fractures several weeks earlier.8 The head trauma suffered
by the infant included an acute fracture of the right parietal bone of the skull and brain
hemorrhaging.9 During treatment for the head trauma, skeletal surveys were taken that
6 Def.'s Notice of Appeal, filed Nov. 15, 2001. With respect to the offense of
endangering the welfare of a child, Defendant was sentenced to pay the costs of
prosecution and to undergo a period of imprisonment of not less than 9 months nor more
than 23 months, and, with respect to the offense of recklessly endangering another
person, Defendant was sentenced to pay the costs of prosecution and to undergo a period
imprisonment of not less than 4 months nor more than 23 months, the sentences to run
concurrently with each other. Order of Ct., Oct. 23, 2001. No additional sentence was
given for the offense of simple assault as it was deemed, for purposes of sentencing, to
merge with the offense of recklessly endangering another person. Id
7 Def.'s Statement of Matters Complained of on Appeal, filed Dec. 3, 2001.
8 N.T. 7.
9 N.T. 41, 48, 182.
2
suggested that the infant had suffered rib fractures several weeks prior to March 27,
2000.~°
Prior to trial, and pursuant to Pennsylvania Rule of Evidence 404(b), Defendant
filed a motion to compel the Commonwealth to provide notice of evidence of prior
crimes, wrongs or acts that the Commonwealth intended to introduce at trial.~ In this
regard, Defendant expressed concern that Stephanie Foster, an adult individual and the
mother of the child, would testify about Defendant's prior convictions for assault.~2
Following a conference (not of record) with President Judge George E. Hoffer, the
motion was denied by Judge Hoffer.~3 At the commencement of trial, Defendant raised
the issue a second time, before the undersigned judge. The court declined to alter the
earlier disposition of the motion following an agreement between counsel that the
Commonwealth would not introduce such evidence at trial without first obtaining a ruling
in favor of its admissibility. ~4
With respect to the allegations that Defendant criminally caused the head trauma
suffered by the child on March 27, 2000, the Commonwealth presented testimony that, at
the time the injuries occurred, Defendant was acting as sole caretaker of Thomas Edward
Quaca, Jr., and that such injuries would not have been accidental.~5
Defendant, in an interview conducted by a caseworker from Cumberland County
Children and Youth Services, stated that he was sole caretaker for the child when the
harm was occasioned, but that the injuries had occurred accidentally when the child fell
from a one- or two-foot high "pile of pillows and blankets," on which Defendant had
l0 N.T. 41, 53-54.
~ Def.'s Mot. To Compel the Commonwealth To File Notice Pursuant to PA.R.E.
404(b), filed Sept. 4, 2001.
~2 N.T. 3-11.
~3 Order of Ct., Sept. 6, 2001 (Hoffer, P.J.).
~4 N.T. 3-11. The Commonwealth did not ask for such a ruling during the course of the
trial.
~ E.g., N.T. 20-21. Defendant was living with, but was not married to, the child's
mother, Stephanie Foster, and watched the child while Foster was at work. N.T. 20-21.
3
placed him to facilitate feeding.16 Defendant claimed that he was in another room when
the injuries occurred, and that he returned to find the child on the floor. After the child's
head began to swell from the trauma, Defendant contacted Foster and Defendant's
mother, who both arrived shortly thereafter and took the child to the haspital.17
Danielle Baal, M.D., an expert in the area of pediatrics and pediatric radiology,la
testified that a fall from the "pile," as described and reenacted by Defendant, could not
have caused the injuries suffered by the child.19 According to Dr. Baal's testimony, a fall
from two feet onto a carpeted floor could not have caused a skull fracture, and, based on
the described location of the "pile" in the room, the child could not have struck his head
on furniture during such a fall.2° Further, Dr. Baal testified that a skull fracture of the
type incurred was more commonly associated with the intentional application of force to
the area afthe injury, that is, to the infant's skull.21
Paul Kanev, M.D., an expert in the field of pediatric neurasurgery and the
physician who treated Thomas Edward Quaca, Jr.,22 testified that the child's injuries were
"nanaccidental" and that Defendant's version of events was unfeasible.23
This evidence, pertaining to the incident of March 27, 2000, clearly supported the
verdict of guilty of simple assault, recklessly endangering another person and
endangering the welfare of a child. Defendant, however, challenges the sufficiency of the
evidence for the jury's additional finding that Defendant had engaged in a course of
16 N.T. 20-23.
17 N.T. 20-23.
la N.T. 35-37.
19 N.T. 45-47, 51-53, 70-72.
20 N.T. 51-53. Dr. Baal testified that, even on a non-carpeted floor, a fall of under three
feet would not cause a skull fracture to a seven-week-old infant. N.T. 46.
21 N.T. 45-47.
22 N.T. 175-81.
23 N.T. 185, 190-195.
4
conduct of endangering the welfare of the chitd.24 With respect to this aspect of the case,
the Commonwealth presented evidence that the rib fractures suffered by the child several
weeks before March 27, 2000, were not accidental and that they occurred when
Defendant was acting as sole caretaker of Thomas Edward Quaca, Jr.25
Dr. Beat testified that, based on her review of both a skeletal survey taken after the
March 27, 2000, incident and a radiograph taken on February 23, 2000, the child had
previously suffered fractures to three of his lower-left ribs.26 Based on the healing of the
ribs that had occurred by March 27, 2000, she estimated that the rib injuries had been
caused approximately two to three weeks eartier.27 Dr. Beat testified that these types of
fractures did not normally occur in the absence of intentionally inflicted injury and that
"the only time [doctors] see [this type of injury] in this age group is abuse, babies that
had been abused.''28
The caseworker for Cumberland County Children and Youth Services who
interviewed Defendant shortly after the incident testified that Defendant had told her that
the only persons who had acted as sole caretaker for the infant were Defendant, Foster
and Defendant's parents.29 The caseworker's testimony concerning her interview with
Defendant may be summarized as follows: When the caseworker initially brought up the
24 Order of Ct., Sept. 10, 2001; see Def.'s Statement of Matters Complained of on
Appeal, filed Dec. 3,2001.
25 N.T. 26-27, 55-59, 81-87, 121-32.
26 N.T. 55-56. The radiograph taken on February 23, 2000, showed that no rib fractures
had occurred before that date. N.T. 55. Although Defendant attempted to evoke testimony
from Dr. Beat that the quality of the radiograph of February 23, 2000, was substandard,
Dr. Beat reiterated that the quality of the items she reviewed was "quite good" and that
her experience allowed her to make an accurate estimation of the time at which the rib
fractures had occurred. N.T. 62-64.
27 N.T. 56.
28 N.T. 58-59. Dr. Beat testified that these injuries would be difficult to detect by a parent
because the only obvious symptom would be increased irritability. N.T. 58.
29 N.T. 26-27. According to the testimony, Defendant also stated that Fester's mother had
been alone with the infant for brief periods, but that she had not acted as caretaker for the
child. N.T. 26-27.
5
subject of the rib fractures, Defendant denied any knowledge of any injuries, but then
stated that Foster's four-year-old child, Ryan, might have caused the injuries while
removing the child from a swing.3° Later, when the caseworker reiterated the suspicious
nature of the injuries, Defendant stated that neither he nor his parents could have caused
the injuries and that Foster was the "number one suspect." Defendant added that "[s]he is
very violent [and] I can't cover up for her.''3~ He alleged that he had been attacked by
Foster previously, and that, although "I have left some marks on her[,] ... that is only
when we argue and she comes after me." He later admitted that he had never seen Foster
be violent with any of her children.32
Following this testimony, the Commonwealth proffered Foster as a witness, who,
according to the Commonwealth's offer of proof, would testify that Defendant had
previously threatened the child. Defendant objected, challenging Foster's competency to
testify on the ground that she did not understand the duty to tell the truth.33 Defendant
based this objection on prior testimony by Foster, given at a dependency hearing, in
which she stated that she "didn't remember" Defendant's previous threats toward the
child.34 This statement, it was argued by Defendant, conflicted with her proffered
testimony and established her incompetency on the aforementioned ground.35 The court,
believing that "the objection [went] more to the weight of the evidence" than to its
admissibility, denied the objection)6
The Commonwealth indicated that it planned to address the subject of
inconsistency by eliciting testimony that Foster "knew she [would have] to go home with
30 N.T. 82-84.
3~ N.T. 85-86.
32 N.T. 86-87.
33 N.T. 121-22.
34 N.T. 121-22, 132.
35 N.T. 121-22.
36 N.T. 123.
6
[Defendant] that night [after testifying at the hearing].''37 Defendant expressed concern
that, through this testimony, the Commonwealth might introduce inadmissible evidence
of prior crimes of Defendant, specifically other instances of abuse. In response, the
Commonwealth "admonished" Foster to state only that she had been fearful of testifying
truthfully at the previous proceeding and not to explain why she was fearful.38
Foster was called as a witness and testified that, when the infant cried, Defendant
would "get very upset" and "violent." According to Foster's testimony, Defendant had
previously cursed at the child and threatened to "smash his little fucking head into the
wall.''39 Foster testified that, at all times during which she was at home and acting as
caretaker for the infant, the child had sustained no injuries, specifically none to the rib
40
area.
During direct examination by the Commonwealth, and in response to questions
regarding Foster's inconsistent statements in the prior hearing, Foster testified as follows:
Well, at that time I was still in a relationship with [Defendant]. At that time
I wasn't working, he was the sole supporter for him and I, and I was afraid
that if I said something to incriminate him that he would be violent with me
later at home.4~
Defendant at this point moved for a mistrial on the ground that the testimony
introduced evidence that Defendant had "been violent in the past toward [Foster,] which
is what prompted her to be fearful of [Defendant]" at the time of the prior hearing.42 The
Commonwealth responded that Foster's testimony could be considered to be
37 N.T. 123.
38 N.T. 123-25, 133.
39 N.T. 129. According to the testimony of the caseworker, Defendant had admitted that
he would often get extremely frustrated from the baby's crying, so much so that Ryan,
Foster's four-year-old son, would tell Defendant to "go sit in the other chair," away from
the infant. N.T. 81.
40 N.T. 130. Foster testified that she left the child with Defendant out of necessity,
because her work schedule required it. N.T. 129.
4~ N.T. 132.
42 N.T. 133.
7
"speculation" as to possible future acts of violence and not specific allegations of past
abuse. The court denied the motion for a mistrial but, upon Defendant's request, and with
the Commonwealth's concurrence, issued a curative instruction to the jury to disregard
Foster's remark.43
DISCUSSION
Statement of Law
General. Section4304 of the Crimes Code, which defines the offense of
endangering the welfare of a child, provides as follows:
(a) Offense defined.--A parent, guardian, or other person supervising
the welfare of a child under 18 years of age commits an offense if he
knowingly endangers the welfare of the child by violating a duty of care,
protection or support.
18 Pa. C.S.A. § 4304. This offense requires the Commonwealth to establish that "the
accused is aware of his/her duty to protect the child[,].., is aware [of]... circumstances
that could threaten the child's physical or psychological welfare[, and].., has taken
action [that]... cannot reasonably be expected to protect the child's welfare."
Commonwealth v. Mackert, 781 A.2d 178, 187 (Pa. Super. Ct. 2001). Generally, all three
elements are satisfied in situations in which a caretaker has engaged in physical abuse of
the child. E.g., id at 187-88.
With respect to the grading of the offense, the section provides as follows:
(b) Grading.--An offense under this section constitutes a
misdemeanor of the first degree. However, where there is a course of
conduct of endangering the welfare of a child, the offense constitutes a
felony of the third degree.
18 Pa. C.S.A. § 4304. A "course of conduct" of child endangerment may be established
by proof that the accused engaged in two related but separate events, both of which
constitute a violation under the statute. See Act of Dec. 6, 1972, P.L. 1482, No. 334, § 1,
as amended, 18 Pa. C.S.A. § 5504(t) (West 1998 & Supp. 2001) (defining "course of
conduct" as a "pattern of actions composed of more than one act over a period of time,
43 N.T. 133-34.
however short, evidencing a continuity of conduct."); see a/so Act of Dec. 6, 1972, P.L.
1339, No. 290, § 3, 1 Pa. C.S.A. § 1921(c) (West 1998 & Supp. 2001) (stating that, when
meaning of phrase is clear in one section of a statute, meaning will be used in interpreting
same phrase in other sections).
Prior Notice of Other Crimes,
Evidence 404(b), the Commonwealth
Wrongs or Acta'. Under Pennsylvania Rule of
is required to "provide reasonable notice in
advance of trial.., of any.., evidence [of other crimes, wrongs or acts] it intends to
introduce at trial." Pa. R. Evid. 404(b)(4). This notice provision "is intended to reduce
surprise and promote early resolution on [issues] of admissibility" when the
Commonwealth plans to introduce evidence that may be subject to challenge under Rule
404. Fed. R. Evid. 404(b); see Pa. R. Evid. 404 cmt. (stating that Pa. R. Evid. 404 is
"consistent" with Fed. R. Evid. 404).
Competency. Pennsylvania Rule of Evidence 601(b), which establishes the
circumstances in which a proffered witness may be judged incompetent to testify,
provides, in pertinent part, as follows:
A person is incompetent to testify if the Court finds that because of a
mental condition or immaturity the person:
(4) does not sufficiently understand the duty to tell the truth.
Pa. R. Evid. 601(b).
When a valid objection to the competency of the witness is raised, the court has an
obligation to hold a hearing on the matter. Common~vealth v. Dolhancryk, 273 Pa. Super.
217, 225, 417 A.2d 246, 250 (1979). However, this obligation arises only if the evidence
suggests that the witness suffers from a "mental condition" that impairs his or her ability
to tell the truth. Pa. R. Evid. 601(b); see Dolhancryk, 273 Pa. Super. at 225, 417 A.2d at
250. Evidence that a witness made false statements in past proceedings is not sufficient to
require a hearing because such evidence bears "only on... credibility, not [the witness's]
ability to tell the truth." Id.
9
Sufficiency of the Evidence. In evaluating the sufficiency of the evidence presented
at trial, the proper test is "whether, viewing the evidence admitted at trial in the light most
favorable to the Commonwealth and drawing all reasonable inferences in the
Commonwealth's favor, there is sufficient evidence to enable the trier of fact to find
every element of the [crime] charged beyond a reasonable doubt." Common~vealth v.
Jones, 449 Pa. Super. 58, 61, 672 A.2d 1353, 1354 (1996) (quoting Commomvea/th v.
Carter, 329 Pa. Super. 490, 495-96, 478 A.2d 1286, 1288 (1984)). The trier of fact is
"free to believe all, part or none of the evidence." Common,yea/th v. Petaccio, 764 A.2d
582, 585 (Pa. Super. Ct. 2000) (quoting Common,yea/th v. Griscavage, 512 Pa. 540, 543,
517 A.2d 1256, 1257 (1986)).
Motion for Mistria/. "Whether to declare a mistrial is a decision which rests within
the sound discretion of the trial court, whose exercise thereof will not be reversed absent
an abuse of such discretion." Common,yea/th v. Bonace, 391 Pa. Super. 602, 608, 571
A.2d 1079, 1082 (1990). Although clear statements of prior, unrelated criminal conduct
of the defendant often warrant the declaration of a mistrial, mere "'passing references" to
prior criminal activity do not require granting a motion for mistrial "unless the record
illustrates definitively that prejudice resulted from the reference." Id. at 608-09, 571 A.2d
at 1082 (quoting Commomvealth v. Nichols, 485 Pa. 1, 4, 400 A.2d 1281, 1282 (1979)).
In determining the prejudicial effect of the statement, relevant considerations include the
nature of the remark, whether it was "intentionally elicited by the Commonwealth," and
whether an immediate curative instruction was given. Bonace, 391 Pa. Super. at 608-09,
571 A.2d at 1082.
Application of Law to Facts
Prior Notice of Other Crimes, Wrongs or Acta'. In the present case, it is believed
that President Judge Hoffer properly denied Defendant's motion to require the
Commonwealth to provide notification of evidence concerning Defendant's prior
assaults.44 Under Pennsylvania Rule of Evidence 404(b), the Commonwealth is required
44 Defendant's "Motion To Compel the Commonwealth To File Notice Pursuant to
PA.R.E. 404(b)" was unclear in terms of the specific evidence Defendant believed that
10
to notify Defendant only when it intends to introduce evidence of other crimes, wrongs or
acts at trial. In this case, the Commonwealth indicated at the outset of trial that it did not
intend to introduce evidence of the type that concerned Defendant and, in fact, had
counseled its witnesses to refrain from giving testimony suggestive of prior criminal
assaults of the Defendant. Nor did the Commonwealth in fact introduce such evidence at
trial. While Foster's testimony that she had feared Defendant might be "violent" arguably
suggested that Defendant had a temper, this oblique expression, with no identification of
a specific prior act, did not implicate Rule 404(b). The Commonwealth was not required
to notify Defendant of bad acts that it neither intended to introduce nor did introduce.
In addition, any alleged impropriety in the pretrial denial of Defendant's Rule
404(b) motion fell short, as the record developed, of producing the prejudicial effect of
the admission of a prior criminal history that might have rendered the error reversible.
See Commonwealth v. Stallworth, 781 A.2d ii0, ii8 n.2 (Pa. 2001) (finding that
defendant had not established requisite prejudice and was not entitled to relief for
Commonwealth's failure to provide Rule 404(b) notice of testimonial evidence of
Defendant's prior threats when defense counsel should have been aware of the prior
threats and had been given an opportunity at trial to object to each witness). Indeed, even
the oblique testimony of Foster as to her fear of Defendant was withdrawn from the
jury's consideration by a curative instruction.
Competency. In the present case, Defendant did not present evidence to support a
valid claim that Stephanie Foster was incompetent to testify. When a party objects to a
the Commonwealth intended to introduce. See N.T. 3-12. However, discussions on the
record at the commencement of trial when Defendant renewed the motion, and the
absence of objection on the part of Defendant during trial to Commonwealth evidence of
angry behavior by Defendant directed toward the child, indicated that the motion was
addressed to Defendant's history of criminal assaults upon others. Prior violence toward
the child, of course, was an "intrinsic" element of the felony offense of endangering the
welfare of a child -- not misbehavior distinct from the crime encompassed by the "other
crimes, wrongs or acts" language of Pennsylvania Rule of Evidence 404. Pa. R. Evid. 404
cmt.; accord Fed. R. Evid. 404(b); see Commonwealth v. Roefaro, 456 Pa. Super. 588,
593,691 A.2d 472, 474 (1997).
ii
witness's competency to testify, the proponent is required to present evidence that the
incompetency results from a "mental condition or immaturity." Here, Defendant made no
allegations and presented no evidence that Foster, an adult individual, suffered from any
condition, mental or otherwise, that would suggest that she could not understand the duty
to tell the truth. In fact, Foster's explanation of her reasons for previously testifying
untruthfully showed that she was and had been conscious of her duty and wished to
explain why she had consciously disregarded it. Because Defendant did not make a
preliminary showing that the allegations of incompetency were based on mental
condition or immaturity, the court was not required to conduct a competency hearing. See
Do/hancryk, 273 Pa. Super. at 225-26, 417 A.2d at 250 (stating that prior inconsistencies
in testimony bear on credibility, not competency); see a/xo Pa. R. Evid. 601(a) ("Every
person is competent to be a witness except as otherwise provided by statute or in these
Rules.").
SufJiciency of the Evidence. In the present case, the evidence, considered in the
light most favorable to the Commonwealth, was sufficient to allow the jury to find that
Defendant had engaged in a course of conduct of endangering the welfare of the child. As
stated by the Pennsylvania Supreme Court:
[W]here an adult is given sole custody of a child of tender years for a
period of time, and, during that time the child sustains injuries which may
have been caused by a criminal agency, the [jury] may examine any
explanation offered and, if they find that explanation to be wanting, they
may reject it and find the person having custody of the child responsible for
the wounds.
Commonwealth v. Meredith, 490 Pa. 303, 306, 416 A.2d 481, 482-83 (1980). Here,
Defendant was properly found responsible for causing the head trauma on March 27,
2000, and it would appear that he does not contest this aspect of the verdict.45 With
respect to the rib fractures suffered by the child several weeks earlier (i.e., the course of
conduct aspect of the verdict), the Commonwealth presented expert testimony that the
45 See Order of Ct., Sept. 10, 2001; see Def.'s Statement of Matters Complained of on
Appeal, filed Dec. 3,2001.
12
injuries were intentionally inflicted. Defendant admitted that, during this period, only he
and Foster acted as sole caretakers for the child, and Foster testified that she had never
harmed the child. Thus, the jury acted within reasonable limits in concluding that the rib
fractures were also caused by Defendant. See id Because the evidence supported the
allegations that Defendant had criminally caused both the skull fracture on March 27,
2000, and the rib fractures several weeks earlier, the evidence was sufficient for a jury to
find that the Defendant had engaged in a course of conduct of endangering the welfare of
a child. See Mackert, 781 A.2d at 186-88 (holding that evidence that the Defendant was
sole caretaker of child during period and that child suffered successive injuries during
that period was sufficient to support finding of course of conduct of endangering the
welfare of children).
Motion for Mistrial. In the present case, the "passing reference" by Foster to her
fear that Defendant might become violent toward her did not mandate a declaration of a
mistrial. With respect to the denial of a mistrial motion, an abuse of discretion may be
found only when the record clearly indicates a prejudicial effect, upon consideration of
factors such as the clarity of the remark, the purposefulness of the Commonwealth in
eliciting the remark, and the immediacy of a curative instruction. Here, the remark in
question occurred when Foster, asked about the reasons for her prior inconsistent
testimony, stated that she had been frightened because "if I said something to incriminate
him that he would be violent with me later at home.''46 This comment did not identify,
expressly or implicitly, any prior act of misconduct on the part of Defendant.
Further, this testimony was elicited unintentionally and in response to a valid line
of questioning regarding Foster's prior inconsistent statements. Before the testimony,
Defendant and the Commonwealth had agreed that Foster would testify only to being
fearful, not the reasons why she was fearful, and the Commonwealth instructed Foster in
this regard. When Foster made the aforementioned remark, the Commonwealth agreed to
a curative instruction, which was given immediately to the jury. The ambiguity in the
46 N.T. 132.
13
passing reference, the unintentional nature of the elicitation of the remark, and the
immediacy of the curative instruction suggest that the reference had little, if any, impact.
Thus, it is believed that the court acted within the limits of its allowable discretion in
denying the motion for a mistrial. See Bonace, 391 Pa. Super. at 610, 571 A.2d at 1083
(finding no abuse of discretion in denying motion for mistrial when remark did not
specify past criminal conduct, the testimony was not elicited purposefully, and the court
issued an immediate curative instruction).
BY THE COURT,
Jaime M Keating, Esq.
Chief Deputy District Attorney
Linda S. Hollinger, Esq.
Assistant Public Defender
Attorney for Defendant
J. Wesley Oler, Jr., J.
14