Com. v. Baltimore, M.

CourtSuperior Court of Pennsylvania
DecidedJuly 3, 2025
Docket1095 MDA 2024
StatusUnpublished

This text of Com. v. Baltimore, M. (Com. v. Baltimore, M.) 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. Baltimore, M., (Pa. Ct. App. 2025).

Opinion

J-S07040-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : MICHAEL ANTHONY BALTIMORE JR. : No. 1095 MDA 2024

Appeal from the Order Entered August 1, 2024 In the Court of Common Pleas of Cumberland County Criminal Division at No(s): CP-21-CR-0002097-2023

BEFORE: NICHOLS, J., McLAUGHLIN, J., and KING, J.

MEMORANDUM BY KING, J.: FILED: JULY 3, 2025

Appellant, the Commonwealth of Pennsylvania, appeals1 from the orders

entered in the Cumberland County Court of Comon Pleas, on July 23, 2024,

and August 1, 2024, denying its motion seeking recusal of the Honorable

Edward E. Guido, President Judge Emeritus (“the trial judge”), from the

underlying criminal matter, due to the alleged bias of his law clerk, Crystle

Craig, Esquire; and asking for a full and fair hearing, before an impartial

____________________________________________

1 Generally, an order denying a Commonwealth’s motion for recusal is interlocutory and is not considered final under Pa.R.A.P. 341. However, where the Commonwealth certifies in its notice of appeal that the denial of the recusal motion substantially handicaps the prosecution, it is appealable as of right under Pa.R.A.P. 311(d). See Commonwealth v. White, 589 Pa. 642, 910 A.2d 648 (2006). In an affidavit attached to its notice of appeal, the Commonwealth asserts that the order denying its request for recusal/disqualification “substantially handicaps the Commonwealth’s prosecution because a biased court order can hamper its ability to present its case,” and, thus, is appealable as of right pursuant to Rule 311(d). See Affidavit, 8/5/24, at 1-2. Therefore, this appeal is proper under Rule 311(d). J-S07040-25

tribunal, to fully develop the record in the matter. We dismiss the appeal as

moot.

The relevant facts and procedural history of this matter are as follows.

In 2021, the Commonwealth charged Appellee, Michael Anthony Baltimore,

Jr., with criminal homicide and related charges and filed notice of its intent to

seek the death penalty. The matter was assigned to the trial judge. During

the pendency of the matter, several incidents occurred between the

Commonwealth’s attorneys and Attorney Craig which ultimately led the

Commonwealth, on July 3, 2024, to file a motion requesting that the trial

judge recuse from the case.2

On August 1, 2024, after reviewing the Commonwealth’s proffered

evidence and resolving any issues of credibility in favor of the Commonwealth,

the court determined that neither an evidentiary hearing nor recusal was

necessary. Consequently, the court entered an order denying the recusal

motion, but the court also precluded Attorney Craig from working on any cases

involving the Commonwealth pending the resolution of any appeal. On August

5, 2024, the Commonwealth timely filed a notice of appeal per Rule 311(d).

On August 6, 2024, the court ordered the Commonwealth to file a Pa.R.A.P.

1925(b) statement of errors complained of on appeal. The Commonwealth

2 Appellee did not take a position on the recusal motion and has not filed a

brief on appeal.

-2- J-S07040-25

timely complied on August 19, 2024.3

Notably, on June 9, 2024, during the pendency of the appeal, the

Commonwealth sent post-submission communication to the parties and this

Court pursuant to Pa.R.A.P. 2501, stating that on May 23, 2025, the trial judge

sua sponte issued an order requesting that the Cumberland County Court

Administrator reassign the matter due to the trial judge’s impending

retirement and the pendency of the instant appeal. 4 On June 5, 2025,

President Judge Albert H. Masland reassigned the matter to the Honorable

Christylee Peck.

On appeal, the Commonwealth raises the following issues for our

review:

I. Whether the trial court erred as a matter of law and abused its discretion when denying the Commonwealth's request to refer the motion to a different judge to handle the recusal matter when its permanent judicial law clerk was a necessary witness and subject of the motion?

II. Whether the trial court erred as a matter of law and committed an abuse of discretion by denying the recusal/disqualification motion without a full and fair hearing with live witness testimony on the matters raised in ____________________________________________

3 Meanwhile, the Commonwealth filed a motion at docket No. CP-21-MD- 0000597-2024, seeking the trial judge’s recusal from all criminal matters due to allegations of bias on the part of Attorney Craig (“the miscellaneous recusal docket”), which the court denied on September 4, 2024. The Commonwealth appealed and, on January 17, 2025, this Court affirmed the denial of relief. See In re Cumberland County District Attorney’s Office, 330 A.3d 471 (Pa.Super. 2025).

4 The Commonwealth has not withdrawn its appeal, nor asserted that the appeal is moot.

-3- J-S07040-25

the motion where its judicial law clerk, and the trial court, was a necessary witness?

III. Whether the trial court erred as a matter of law and committed an abuse of discretion by denying the Commonwealth’s Motion to Recuse/Disqualify [the trial judge]?

IV. Whether the trial court erred as a matter of law and abused its discretion by allowing the law clerk, a necessary witness in the proceeding, to participate in the decision and disposition of the Commonwealth’s motions?

(Commonwealth’s Brief at 5-6).

As a preliminary matter, we observe:

As a general rule, an actual case or controversy must exist at all stages of the judicial process, or a case will be dismissed as moot. An issue can become moot during the pendency of an appeal due to an intervening change in the facts of the case or due to an intervening change in the applicable law. In that case, an opinion of this Court is rendered advisory in nature. An issue before a court is moot if in ruling upon the issue the court cannot enter an order that has any legal force or effect....

* * *

[T]his Court will decide questions that otherwise have been rendered moot when one or more of the following exceptions to the mootness doctrine apply: 1) the case involves a question of great public importance, 2) the question presented is capable of repetition and apt to elude appellate review, or 3) a party to the controversy will suffer some detriment due to the decision of the trial court.

In re D.A., 801 A.2d 614, 616 (Pa.Super. 2002) (en banc) (internal citations

and quotation marks omitted). “The concept of mootness focuses on a change

that has occurred during the length of the legal proceedings.” In re Cain,

527 Pa. 260, 263, 590 A.2d 291, 292 (1991). “If an event occurs that renders

-4- J-S07040-25

impossible the grant of the requested relief, the issue is moot and the appeal

is subject to dismissal.” Delaware River Preservation Co., Inc. v. Miskin,

923 A.2d 1177, 1183 n.3 (Pa.Super. 2007). Importantly, “mootness, however

it may have come about, simply deprives us of our power to act; there is

nothing for us to remedy, even if we were disposed to do so. We are not in

the business of pronouncing that past actions which have no demonstrable

continuing effect were right or wrong.” Spencer v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Spencer v. Kemna
523 U.S. 1 (Supreme Court, 1998)
In Re Gross
382 A.2d 116 (Supreme Court of Pennsylvania, 1978)
Commonwealth v. White
910 A.2d 648 (Supreme Court of Pennsylvania, 2006)
Delaware River Preservation Co. v. Miskin
923 A.2d 1177 (Superior Court of Pennsylvania, 2007)
Commonwealth v. Buehl
462 A.2d 1316 (Supreme Court of Pennsylvania, 1983)
In Re Cain
590 A.2d 291 (Supreme Court of Pennsylvania, 1991)
In re D.A.
801 A.2d 614 (Superior Court of Pennsylvania, 2002)
Bottomer v. Progressive Casualty Insurance
859 A.2d 1282 (Supreme Court of Pennsylvania, 2004)
In Re: Cumb. Co. DA's Office
2025 Pa. Super. 11 (Superior Court of Pennsylvania, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
Com. v. Baltimore, M., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-baltimore-m-pasuperct-2025.