Cases | Commonwealth v. Means, 773 A.2d 143 (Pa. 2001) | 2018
The defendant was convicted of first-degree murder and other charges related to the murder of one victim and the assault and robbery of another. During the penalty phase of a bench trial, the defendant moved to exclude victim impact evidence, arguing that the sections of Pennsylvania’s death penalty statute that permitted the introduction of such evidence were unconstitutional. The trial court sustained the defendant’s motion to preclude the introduction of victim impact testimony and declared portions of Pennsylvania’s death penalty statute unconstitutional, finding that they failed to establish sufficient procedural safeguards regarding the introduction of victim impact testimony during the penalty phase of a capital case. On direct appeal, the Supreme Court of Pennsylvania reversed the decision of the trial court. The court noted that Pennsylvania jurisprudence favors the introduction of all relevant evidence during a capital sentencing proceeding, and that Pennsylvania’s sentencing scheme does not limit this evidence in the penalty phase to only the information necessary to establish aggravating and mitigating circumstances. The court found further that the trial judges of the Commonwealth could adequately prevent unduly prejudicial and inflammatory information from entering into the jury’s deliberations in the guise of victim impact testimony. Where the Commonwealth establishes that the victim’s death did in fact have an impact on the victim’s family, the trial court has discretion over the testimony admitted.