Com. v. Abdul-Ali, J.

2025 Pa. Super. 70
CourtSuperior Court of Pennsylvania
DecidedMarch 24, 2025
Docket588 MDA 2024
StatusPublished

This text of 2025 Pa. Super. 70 (Com. v. Abdul-Ali, J.) 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. v. Abdul-Ali, J., 2025 Pa. Super. 70 (Pa. Ct. App. 2025).

Opinion

J-S42018-24 2025 PA Super 70

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : JARED RAHIM ABDUL-ALI : : Appellant : No. 588 MDA 2024

Appeal from the Judgment of Sentence Entered April 12, 2024 In the Court of Common Pleas of Schuylkill County Criminal Division at No(s): CP-54-CR-0000443-2023

BEFORE: LAZARUS, P.J., BECK, J., and BENDER, P.J.E.

OPINION BY BECK, J.: FILED: MARCH 24, 2025

Jared Rahim Abdul-Ali (“Abdul-Ali”) appeals from his judgment of

sentence imposed by the Schuylkill County Court of Common Pleas (“trial

court”) following his conviction for first-degree murder and other crimes

committed against Destiny Duckett (“Duckett”), the mother of his two-month-

old child, A.C. Abdul-Ali argues that the trial court erred by failing to suppress

inculpatory statements and abused its discretion in admitting evidence of prior

abuse involving the victim. We affirm.

At approximately 11:00 a.m. on Monday, February 13, 2023, Jennifer

McCabe, the manager of Duckett’s apartment complex, performed a wellness

check after Duckett’s family was unable to reach her. N.T., 4/1/2024, at 65.

McCabe saw Duckett’s deceased body on the bedroom floor. Id. at 67. A.C.

was crying nearby. Id. at 69. She called 911, and police officers observed

signs of a struggle. Id. at 93. A forensic pathologist, Dr. Wayne Ross, opined J-S42018-24

that the assailant used a “ligature … to pull into the front and sides of the neck

from behind.” N.T., 4/2/2024, at 150. The autopsy also indicated that the

attacker manually strangled Duckett “with dual hands in the front and the

back compressing the neck[.]” Id. at 150-51. Additionally, bruising to

Duckett’s heart and lungs indicated that the attacker applied “a tremendous

amount of force … on top of [her] chest” during the attack. Id. at 161. Dr.

Ross opined that, based on rigor mortis and body temperature, Duckett died

no later than 5:00 a.m. on February 13. Id. at 170. He agreed that the death

could have occurred sometime between 8:00 p.m. Sunday to 1:00 a.m.

Monday. Id.

Detective Joseph Krammes knew that Duckett had a protection from

abuse (“PFA”) order against Abdul-Ali and the detective thus visited My

Father’s House, a homeless shelter that Abdul-Ali was known to frequent.

N.T., 4/1/2024, at 94. At approximately 1:15 p.m. he spoke to Abdul-Ali, who

was crying and claimed that “he had a ‘gut feeling’ that something bad had

happened to somebody close to him.” Id. at 95-96. Abdul-Ali voluntarily

accompanied officers to City Hall, where Detective Krammes and Captain Kirk

Becker interviewed him. Id. at 98-99. The officers read Abdul-Ali his

Miranda1 warnings, and Abdul-Ali signed a waiver before speaking with the

____________________________________________

1 Miranda v. Arizona, 384 U.S. 436 (1966).

-2- J-S42018-24

officers. A little over an hour after the interview had commenced, Abdul-Ali

invoked his right to silence.

Three days later, officers executed a search warrant for Abdul-Ali’s DNA;

he agreed to speak with them again at their offering and was transported to

City Hall for another interview. N.T., 4/2/2024, at 219-20. Abdul-Ali admitted

during this conversation with police that he had visited Duckett on the evening

of the 12th and violated the PFA order. Trial Court Opinion, 6/25/2024, at 6.2

He claimed Duckett told him “she wished she could ‘put the PFA in the past,’

and was getting it dropped.’” Id. at 7. Abdul-Ali saw scratches on her neck,

which she claimed was from their child. Id. He explained that if neighbors

heard sounds from the apartment, it was because he “did not believe” her

story. Id. He “was always asking her if she was having sex with other men,”

id. at 8, and argued with her because “he was trying to ‘figure out’ who had

been in the apartment.” Id. at 7. However, he stated that he calmed down

after their discussion and he and Duckett had sex that evening, with her

asking him to put his hand on her neck. Id. at 12. He denied strangling her

and stated that Duckett was fine when he left her apartment that evening.

2 All interviews were recorded and substantial portions were played to the jury. However, the videos were not included in the certified record. “It is an appellant’s duty to ensure that the certified record is complete for purposes of review.” Commonwealth v. Reed, 971 A.2d 1216, 1219 (Pa. 2009) (citation omitted). The trial court’s opinion transcribed the key portions, and Abdul-Ali does not contest its accuracy. Indeed, he quotes the trial court’s transcription in his brief before this Court. See Abdul-Ali’s Brief at 19. We therefore rely on those transcriptions so that we can adjudicate Abdul-Ali’s appeal.

-3- J-S42018-24

Id. at 8. Abdul-Ali claimed that he left the apartment at her request as “she

did not want him to get in trouble” because of the PFA. Id. at 13. He stated

he rode his bike to a location near a church, where he spent the evening. Id.3

He insisted that Duckett was unharmed when he left the building, and the

interview ended when Abdul-Ali invoked his right to an attorney, which

occurred after he invoked his right to silence once again.

While being transported back to prison, Abdul-Ali offered to show police

where he had slept that evening. Id. at 14. Upon reaching the location,

Abdul-Ali asked if he could “speak again about [Duckett]’s death and the

investigation.” Id. at 15. During this final interview, Abdul-Ali claimed he

and Duckett argued about a movie Duckett had shown to their child.

According to his statement, Duckett “attacked him,” and he “tried to calm

[her] down by restraining her and putting his hands on her neck for her to go

to ‘sleep.’” Id. He said that Duckett then “calmed down, told him to let go,

and ... started to snore[.]” Id. He then left the apartment “because he did

not want to get in trouble for being there.” Id. at 16. He insisted that Duckett

was breathing when he left and that he did not use any kind of ligature. Id.

Abdul-Ali filed a motion to suppress all statements made to police after

he terminated the interview on February 13 by invoking his right to silence.

He averred that his decision to submit to an interview on February 16 at City

3 Abdul-Ali stated he had left his jacket and other “stuff” at this location. See Trial Court Opinion, 6/25/2024, at 14.

-4- J-S42018-24

Hall should be suppressed because he had “indicated he no longer wished to

talk” on February 13 and the officers violated the Fifth Amendment by

attempting to resume questioning. Motion to Suppress, 7/17/2023, ¶ 9.

Turning to the statements given after the first February 16 interview

concluded, which occurred in the police vehicle after leaving City Hall, Abdul-

Ali noted that he had invoked his right to an attorney prior to those

conversations. He argued that all subsequent statements had to be

suppressed as the “police violated [Abdul-Ali]’s Fifth Amendment rights[.]”

Id. Specifically, he argued that the police failed to “contact[] an attorney …

or allow[] him to try to contact an attorney” before conducting another

interview. Id. ¶ 8. In a supplemental motion, Abdul-Ali included additional

factual allegations and cited a violation of his Sixth Amendment rights.

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