Com. of Pa. v. Mangel

181 A.3d 1154
CourtSuperior Court of Pennsylvania
DecidedMarch 15, 2018
DocketNo. 703 WDA 2017; No. 704 WDA 2017
StatusPublished
Cited by77 cases

This text of 181 A.3d 1154 (Com. of Pa. v. Mangel) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Com. of Pa. v. Mangel, 181 A.3d 1154 (Pa. Ct. App. 2018).

Opinion

OPINION BY MUSMANNO, J.:

The Commonwealth of Pennsylvania appeals from the Order denying its Motion in Limine to introduce Facebook posts and messages allegedly authored by defendant Tyler Kristian Mangel ("Mangel"). We affirm.

On June 26, 2016, Nathan Cornell ("Cornell") was assaulted at a graduation party. On July 15, 2016, a Criminal Complaint was filed against Mangel, at CR 2939 of 2016, charging him with aggravated assault, simple assault and harassment of Cornell. See 18 Pa.C.S.A. §§ 2702(a)(1), 2701(a)(1), 2709(a)(1). At CR 2940 of 2016, the Commonwealth filed a separate Criminal Complaint against Matthew Robert Craft ("Craft"), charging him with the same offenses. The criminal cases against Mangel and Craft were consolidated for trial. Attached to the Criminal Complaints was an Affidavit of Probable Cause,1 which indicated that Cornell had told police that "several fights ensued as a result of an undetermined amount of people arriving" at the party. Affidavit of Probable Cause, 7/15/16, at 1. Cornell had further stated that "he was walking away from where these altercations were taking place when he was struck in the back of the head[,] knocked to the ground[,]" and "was repeatedly kicked and punched by [ ] Mangel [ ] and [ ] Craft [ ]." Id. Cornell also stated that he did not know Mangel or Craft, "nor had he been in contact with them during the course of the night, but he was *1156able to identify them as a result of being shown Facebook pictures by his family." Id. As a result of the assault, Cornell suffered facial lacerations, a broken maxilla bone, a broken nasal bone, and seven of his teeth were knocked out. Id.

On March 15, 2017, the Commonwealth filed a Motion for Provider to Provide Subscriber Information, pursuant to 18 U.S.C. § 2307(c) and 18 Pa.C.S.A. § 5743(c) and (d), seeking to obtain Mangel's Facebook records. The trial court granted the Motion on that same date. At the time of jury selection on May 8, 2017, the Commonwealth filed a Motion in Limine to introduce screenshots of certain pages of a Facebook account for "Tyler Mangel," consisting of undated online and mobile device "chat" messages. See Motion in Limine , 5/8/17, at Appendices A-C. The Commonwealth also sought to introduce a Facebook screenshot wherein a photograph of purportedly bloody hands had been posted by "Justin Jay Sprejum Hunt." See id.

On May 8, 2017, the trial court conducted a hearing on the Motion, at which the Commonwealth presented the testimony of Erie County Detective Anne Styn ("Detective Styn"), whom the trial court qualified as an expert in computer forensics. N.T., 5/8/17, at 7. Detective Styn testified that she had received a request from the Commonwealth to determine the owner of a particular Facebook account, bearing the name "Tyler Mangel," and was provided with "Facebook screenshots captured from online, as well as mobile device chats" of that account taken by Trooper Schaeffer2 of the Pennsylvania State Police. Id. at 7-8, 12-14.

Detective Styn then "conducted a search on Facebook for the individual's name, Tyler Mangel, in which only one name had populated at that time [as] being [']Tyler Mangel.[']" N.T., 5/8/17, at 9. Detective Styn then compared the Facebook account that she had located to the screenshots that she had received from the Commonwealth, and noticed that both the screenshots and the Facebook account bore name "Tyler Mangel;" both listed the account holder as living in Meadville, Pennsylvania; and some of the photographs on the screenshots were the same as those on the Facebook account. Id. at 9. In the "about" section of the Facebook account located by Detective Styn, the page indicated that the individual had attended Meadville High School. Id. Detective Styn further testified that the username associated with the Facebook account was "Mangel17." Id. at 11. Upon receiving the requested subscriber records from Facebook, Detective Styn determined that the account was created by using the first name "Tyler" and the last name "Mangel," and the registered email addresses of mangel17@facebook and tylertkm@hotmail.com. Id. The Facebook subscriber records also indicated that the Facebook account had been verified by the cell phone number (814) 573-4409. Id. at 11-12. Detective Styn then obtained a court order for the Verizon subscriber records associated with this phone number, which identifed the owner of the number as "Stacy Mangel," residing at 10866 Pettis Road, Meadville, Pennsylvania. Id. at 12. The trial court took judicial notice of the fact that this particular address is the same as the address listed in the Criminal Complaint filed against Mangel. Id.

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Cite This Page — Counsel Stack

Bluebook (online)
181 A.3d 1154, Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-of-pa-v-mangel-pasuperct-2018.