Com. v. Banks, E.

CourtSuperior Court of Pennsylvania
DecidedMarch 14, 2025
Docket539 MDA 2024
StatusUnpublished

This text of Com. v. Banks, E. (Com. v. Banks, E.) 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. Banks, E., (Pa. Ct. App. 2025).

Opinion

J-S45041-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : ERIC THEADY BANKS : : Appellant : No. 539 MDA 2024

Appeal from the PCRA Order Entered March 14, 2024 In the Court of Common Pleas of York County Criminal Division at No(s): CP-67-CR-0001361-2018

BEFORE: OLSON, J., DUBOW, J., and McLAUGHLIN, J.

MEMORANDUM BY McLAUGHLIN, J.: FILED MARCH 14, 2025

Eric Theady Banks appeals from the order denying his Post Conviction

Relief Act (“PCRA”) petition. See 42 Pa.C.S.A. §§ 9541-9546. He argues that

trial counsel was ineffective for failing to withdraw due to his prior

representation of a potential Commonwealth witness and for failing to further

question or strike a juror who indicated she knew two of the Commonwealth’s

witnesses. We affirm.

The facts of this case were previously summarized as follows:

The events occurred at a private residence [address omitted] at approximately 10:30 p.m. on November 18, 2017. A sizable group of family and friends had gathered at the residence due to the family receiving news that an aunt had been diagnosed with terminal cancer. Between 10:30 p.m. and 11:00 p.m., [Banks] arrived at the residence and began to argue with his then girlfriend [name omitted]. At this point the victim, [L.T.], told [Banks] to leave because there were several children present. In response, [Banks] opened his coat and flashed [L.T.] a gun under the coat. He J-S45041-24

did this three or four times. [L.T.] testified that she was not initially afraid because [Banks] was known to her from a previous relationship years earlier. However, when the children ran toward the scene, she realized the potential danger of the situation and immediately began to fear an imminent threat [Banks] posed to her and her family. At that point the women of the household, including [the then girlfriend and L.T.], managed to get him to leave the house. Shortly thereafter, multiple people reported hearing gunshots immediately after [Banks] left the house and before he drove away. Three shell casings were found on the ground approximately one block away from the residence.

On November 7, 2018, the case proceeded to a jury trial. At the close of evidence, the parties stipulated that [Banks] did not have a concealed carry permit and was not permitted to carry a firearm. On November 8, 2018, the jury found [Banks] guilty of simple assault, persons not to possess firearms and carrying a firearm without a license. The jury acquitted [Banks] of reckless endangerment.

On January 30, 2019, the court imposed the following consecutive sentences: 8-16 years’ imprisonment for persons not to possess firearms, 3½-7 years’ imprisonment for carrying firearms without a license, and 1-2 years’ imprisonment for simple assault. [Banks] filed timely post- sentence motions, which the court denied, and a timely notice of appeal.

Commonwealth v. Banks, No. 200 MDA 2020, 2020 WL 7706756, at *1

(Pa.Super. filed Dec. 29, 2020) (unpublished mem.) (citation omitted, some

alterations in original).

This Court affirmed Banks’ judgment of sentence. See id. Banks filed a

petition for allowance of appeal with the Pennsylvania Supreme Court. While

that petition was pending, Banks filed a pro se PCRA petition on March 23,

2021. The court appointed counsel, who filed an amended PCRA petition. In

-2- J-S45041-24

the meanwhile, the Pennsylvania Supreme Court denied allowance of appeal

on July 7, 2021.

Subsequently, on April 28, 2022, the PCRA court held a hearing on the

petition, in which Banks’ trial counsel, Clarence Allen, Esquire, testified. The

PCRA court summarized the testimony at the hearing as follows:

Attorney Allen took the stand and testified that he had represented [Banks]. Attorney Allen testified that, at that time, he was also representing clients in matters outside of criminal law; however, he denied representing [potential Commonwealth witness O]nissa Tyler at that time. Attorney Allen stated that he had represented Ms. Tyler a few years prior in a custody matter that had been resolved, but Attorney Allen admitted that he had not withdrawn as counsel and was still counsel of record for Ms. Tyler. Attorney Allen’s understanding was that Ms. Tyler would have testified that [Banks] had been present at a party on the day in question and that this testimony would have been detrimental to [Banks]. Attorney Allen testified that he talked to the witness and was led to believe that her testimony was not going to help [Banks]; but, rather, Ms. Tyler’s testimony would have solidified the testimony of other witnesses against [Banks]. In addition to affirming that [Banks] was present at a party, Ms. Tyler would have been one of two witnesses to testify that they had seen [Banks] in possession of a firearm that night. Attorney Allen believed that Ms. Tyler would have been a key witness for the Commonwealth.

PCRA counsel questioned Attorney Allen about Ms. Tyler being unavailable for trial because of Attorney Allen stipulating that she was unavailable for trial. Attorney Allen responded that Ms. Tyler was, at the time of trial, in the hospital or had just gotten out of the hospital. Attorney Allen was questioned about his statements at trial, regarding the stipulation that Ms. Tyler was unavailable to testify as a witness, that Ms. Tyler had been scheduled to meet with Attorney Allen at his office in the weeks preceding trial — despite Attorney Allen describing Ms. Tyler, at the PCRA proceedings, as a former client at the time of trial. Attorney

-3- J-S45041-24

Allen responded that he had wanted to speak with Ms. Tyler, prior to trial, about what had happened at the party, but that he discovered that Ms. Tyler was in the hospital.

Turning to jury selection, Attorney Allen testified that he remembered a juror admitting to knowing LaTia Tyler and [O]nissa Tyler. The juror knew these witnesses from the community. Attorney Allen could not recall whether the Commonwealth had followed up with the juror, but it was his belief that the [c]ourt had inquired whether the juror would be able to render a fair decision. Following PCRA counsel presenting the section of the trial transcript dealing with voir dire, Attorney Allen agreed that the sections dealing with the juror in question, Juror 19, did not include questioning by either counsel or the judge regarding whether Juror 19 could be impartial. However, Attorney Allen thought that Juror 19 might have been helpful to the defense as she was the only African American in the jury pool. In fact, Attorney Allen discussed this with [Banks] and “we felt we wanted that particular juror as a juror because we - - again, an African American juror and [sic] we felt she would be more sympathetic to [Banks’] case.” Attorney Allen disagreed with PCRA counsel’s portrayal of Attorney Allen’s stance as being that the race of a juror was more important than the possibility of that juror being biased towards the Commonwealth witnesses. Attorney Allen agreed that he did not probe the depth of that juror’s knowledge of the witnesses whom the juror knew from the community.

On cross-examination, Attorney Allen testified to his belief, at trial, that Ms. [O]nissa Tyler’s testimony would have been detrimental to his client and that her unavailability was a benefit to [Banks]. Attorney Allen reaffirmed that his representation of Ms. Tyler had been in a custody matter some two or three years prior and that he still knew her family. Attorney Allen confirmed that [Banks] is African American.

PCRA Court Opinion, filed 9/16/22, at 3-6 (citations to transcript omitted,

emphasis removed, some alterations in original).

-4- J-S45041-24

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

Related

Commonwealth v. Burke
781 A.2d 1136 (Supreme Court of Pennsylvania, 2001)
Commonwealth v. Robinson
864 A.2d 460 (Supreme Court of Pennsylvania, 2004)
Commonwealth v. Collins
957 A.2d 237 (Supreme Court of Pennsylvania, 2008)
Commonwealth v. Sneed
45 A.3d 1096 (Supreme Court of Pennsylvania, 2012)
Commonwealth v. Chmiel
889 A.2d 501 (Supreme Court of Pennsylvania, 2005)
Commonwealth v. Colson
490 A.2d 811 (Supreme Court of Pennsylvania, 1985)
Commonwealth v. Rivera
10 A.3d 1276 (Superior Court of Pennsylvania, 2010)
Commonwealth v. Presley
193 A.3d 436 (Superior Court of Pennsylvania, 2018)
Commonwealth v. Sepulveda
55 A.3d 1108 (Supreme Court of Pennsylvania, 2012)
Commonwealth v. Spotz
84 A.3d 294 (Supreme Court of Pennsylvania, 2014)
Commonwealth v. Tharp
101 A.3d 736 (Supreme Court of Pennsylvania, 2014)
Com. v. Velazquez, G.
2019 Pa. Super. 243 (Superior Court of Pennsylvania, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Com. v. Banks, E., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-banks-e-pasuperct-2025.