Com. v. Beatty, B.

2025 Pa. Super. 96
CourtSuperior Court of Pennsylvania
DecidedMay 5, 2025
Docket1982 EDA 2024
StatusPublished

This text of 2025 Pa. Super. 96 (Com. v. Beatty, B.) 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. Beatty, B., 2025 Pa. Super. 96 (Pa. Ct. App. 2025).

Opinion

J-S08031-25 2025 PA Super 96

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : BRUCE A. BEATTY : : Appellant : No. 1982 EDA 2024

Appeal from the PCRA Order Entered July 8, 2024 In the Court of Common Pleas of Montgomery County Criminal Division at No(s): CP-46-CR-0006956-2018

BEFORE: DUBOW, J., KUNSELMAN, J., and FORD ELLIOTT, P.J.E. 

OPINION BY FORD ELLIOTT, P.J.E.: FILED MAY 5, 2025

Bruce A. Beatty appeals from the order 1 dismissing his timely first

petition filed pursuant to the Post Conviction Relief Act (“PCRA”), 42 Pa.C.S.

§§ 9541-9546. A jury found him guilty of attempted involuntary deviate

sexual intercourse (“IDSI”) with a child, aggravated indecent assault with a

person less than thirteen years old, aggravated indecent assault of a child,

indecent assault of a person less than thirteen years old, unlawful contact with

a minor, and corruption of minors.2 On collateral review appeal, Beatty asserts

that his counsel was ineffective at four discrete points of his trial. After

____________________________________________

 Retired Senior Judge assigned to the Superior Court.

1 The docket reflects that delivery of the order dismissing Beatty’s petition was

mailed on July 8, 2024. We have amended the caption accordingly. See Pa.R.A.P. 108(a)(1), (d)(1).

2 18 Pa.C.S. §§ 901(a), 3125(a)(7), 3125(b), 3126(a)(7), 6318(a)(1), 6301(a)(1)(ii), respectively. J-S08031-25

thorough review, we affirm.

As summarized by this Court in his direct appeal,

S.F., the victim in this case, was eleven years old when the incidents occurred. [Beatty] was S.F.’s mother’s boyfriend at the time the assaults occurred. [Beatty] visited S.F.’s home approximately twice a month. S.F. lived with her brother, 25-year- old sister, and mother in a four-bedroom home at the time of the assaults.

A criminal complaint was filed against [Beatty] on August 20, 2018[.] alleging that [Beatty] committed acts of sexual misconduct against S.F. The Commonwealth charged [Beatty] with [the above-referenced offenses]. A jury trial commenced on July 17, 2019.

At trial, S.F. testified that she was currently 13 years old, in eighth grade and working at a summer camp as a counselor for kids. S.F. testified that there were three incidents involving [Beatty]. She stated that the first incident occurred approximately a year prior to trial. The first incident occurred in her mother’s bedroom when [Beatty] touched her breast over her bathrobe. [Beatty] moved her to sit on his lap and touched her breast area.

S.F. testified the second incident also occurred in her mother’s bedroom when [Beatty] offered to give her a massage, rubbed her back under her shirt, flipped her over[,] and touched her breasts with both his hands under her shirt and over her bra. She stated that [Beatty] began rubbing her vagina under her underwear and pulled his penis out and put her hand on it. [Beatty] also asked S.F. to put his penis in her mouth. S.F. testified that [Beatty’s] penis felt hard and that a clear liquid came out of his penis when her hand was still on it. S.F. stated that her hand was moving up and down while her hand was on [Beatty’s] penis. She testified that the third incident also occurred in her mother’s bedroom. S.F. stated that her legs were in the air and [Beatty] asked if he could lick her vagina. S.F. testified that [Beatty] did not lick her vagina because she had to leave the house.

Commonwealth v. Beatty, 2021 WL 2769854, *1 (Pa. Super., filed July 2,

2021) (unpublished memorandum) (record citations omitted). After a jury

-2- J-S08031-25

found Beatty guilty of the above-mentioned offenses, the court sentenced him

to an aggregate ten to twenty years of incarceration. We affirmed his

judgment of sentence, and our Supreme Court denied his petition for

allowance of appeal. See Commonwealth v. Beatty, 271 A.3d 874 (Pa.

2022) (table).

Beatty filed the present petition, his first, on March 3, 2023. After an

evidentiary hearing was held in which his trial counsel testified, the court

denied Beatty’s petition. Beatty timely filed an appeal from the court’s denial

of relief and, after being directed to do so, complied with Pennsylvania Rule

of Appellate Procedure 1925(b).

On appeal, Beatty avers that his trial counsel was ineffective.

Specifically, Beatty raises the following issues for our review:

1. Should trial counsel have objected to testimony that he did not return a phone call from the affiant and instead was seated next to counsel at trial because this testimony unfairly exploited his decision to remain silent in a case in which he did not testify?

2. Should trial counsel have objected to the prosecutor’s opening and closing argument, which suggested that the Pennsylvania Legislature had specific opinions about this case in particular, that the Legislature wanted the jury to convict, and that the burden of proof was lower in sexual assault cases than in other types of criminal cases?

3. Did trial counsel provide ineffective assistance of counsel in failing to request the inconsistent statement jury instruction where counsel’s entire defense at trial was that the complainant made inconsistent statements?

4. Should trial counsel have objected to the improper expert testimony from a former member of the prosecution team

-3- J-S08031-25

regarding the “typical” behavior of alleged sexual assault victims because the expert was not qualified and the testimony was irrelevant, unfairly prejudicial, unreliable, and improperly bolstered the credibility of complainant?

See Appellant’s Brief, at 4-5.3

“We review the denial of PCRA relief to decide whether the PCRA court’s

factual determinations are supported by the record and are free of legal error.”

Commonwealth v. Brown, 196 A.3d 130, 150 (Pa. 2018). “When supported

by the record, the PCRA court’s credibility determinations are binding on this

Court, but we apply a de novo standard of review to the PCRA court’s legal

conclusions.” Id.

Here, across all four questions presented, Beatty argues that his trial

counsel was ineffective. Arguments of this nature invoke a well-settled

standard of review from this Court:

With respect to claims of ineffective assistance of counsel, counsel is presumed to be effective, and the petitioner bears the burden of proving to the contrary. To prevail, the petitioner must plead and prove, by a preponderance of the evidence, the following three elements: (1) the underlying claim has arguable merit; (2) counsel had no reasonable basis for his or her action or inaction; and (3) the petitioner suffered prejudice as a result of counsel’s action or inaction. With regard to the second prong (reasonable basis), “we do not question whether there were other more logical courses of action which counsel could have pursued; rather, we must examine whether counsel’s decisions had any reasonable basis.” We will hold that counsel’s strategy lacked a reasonable basis only if the petitioner proves that a foregone alternative “offered a potential for success substantially greater than the course actually pursued.” Our review of counsel’s performance ____________________________________________

3 The Commonwealth did not file a brief in this case.

-4- J-S08031-25

“must be highly deferential.” To establish the third element (prejudice), the petitioner must show that there is a reasonable probability that the outcome of the proceedings would have been different but for counsel’s action or inaction.

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2025 Pa. Super. 96, Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-beatty-b-pasuperct-2025.