Com. v. Brown, V.

CourtSuperior Court of Pennsylvania
DecidedNovember 30, 2020
Docket155 MDA 2019
StatusUnpublished

This text of Com. v. Brown, V. (Com. v. Brown, V.) 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. Brown, V., (Pa. Ct. App. 2020).

Opinion

J-A16014-20

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : VANESSA BROWN : : Appellant : No. 155 MDA 2019

Appeal from the Judgment of Sentence Entered November 30, 2018 In the Court of Common Pleas of Dauphin County Criminal Division at No(s): CP-22-CR-0000525-2015

BEFORE: PANELLA, P.J., STABILE, J., and MUSMANNO, J.

MEMORANDUM BY MUSMANNO, J.: FILED NOVEMBER 30, 2020

Vanessa Brown (“Brown”) appeals from the judgment of sentence

entered following her conviction of five counts of conflict of interest, one count

of bribery, and one count of statement of financial interests.1 We affirm.

In 2010, Pennsylvania Attorney General Tom Corbett (“Attorney General

Corbett”) launched an undercover sting operation to ferret out public

corruption in state government. To facilitate that investigation, the Attorney

General’s Office obtained the cooperation of Tyron Ali (“Ali”) by agreeing not

to prosecute him for fraud if he assisted with the investigation. Ali presented

himself to members of the Pennsylvania legislature as a lobbyist seeking to

advance legislation on behalf of his clients and willing to pay for it. Ali

____________________________________________

1See 65 Pa. C.S.A. § 1103(c), 18 Pa. C.S.A. § 4701(a)(1), and 65 Pa. C.S.A. § 1105(a). J-A16014-20

captured several members of Philadelphia’s state House delegation on tape

accepting relatively modest cash payments in exchange for their votes on

legislation. The evidence from the investigation – specifically, the tape

recordings – resulted in the prosecution and conviction of these legislators.

This appeal involves one of the legislators who was ensnared in the undercover

sting operation.

Vanessa Lowry Brown (“Brown”) was a member of the Pennsylvania

House of Representatives. Like all elected officials, Brown needed to raise a

significant sum of money for her upcoming election to scare off potential

challengers. However, Brown struggled to raise the necessary funds. Fearing

a contested election, Brown approached Ali for help with meeting her

fundraising goal. Ali agreed to raise money for Brown’s reelection campaign,

but made clear that he expected Brown to promote his client’s interests in

Harrisburg. Brown responded by using her position as a legislator to assist

Ali.

Over the next several months, Ali provided Brown with multiple cash

payments to secure her vote on various pieces of legislation in the House. In

one instance, Ali asked Brown to vote “no” on legislation requiring voters to

show some form of identification at polling places. Brown voted against the

voter identification measure in the House. Shortly after the vote, Ali appeared

in Brown’s office and handed her an envelope containing $2,000 in cash.

Unbeknownst to Brown, Ali recorded the illegal transaction on tape.

-2- J-A16014-20

Despite evidence that Brown had accepted money in exchange for

favorable votes on legislation, Pennsylvania Attorney General Kathleen Kane

(“Attorney General Kane”) declined to charge Brown due to concerns about

the investigation.2 The Attorney General’s Office then referred the case to the

Philadelphia District Attorney’s Office. Thereafter, Philadelphia District

Attorney R. Seth Williams (“Williams”), in conjunction with Dauphin County

District Attorney Ed Marsico (“District Attorney Marsico”), impaneled a grand

jury to investigate the corruption allegations against Brown.

After hearing testimony from numerous witnesses, including Brown, and

examining the evidence, the grand jury returned a presentment

recommending criminal charges. The judge overseeing the investigating

grand jury then directed the appropriate jurisdiction, Dauphin County, to file

charges against Brown. The Dauphin County District Attorney’s Office filed a

Criminal Complaint charging Brown with the above-described crimes: five

counts of conflict of interest, one count of bribery, and one count of statement

of financial interests.

In the years that followed, a series of unexpected events upended and

delayed the corruption case against Brown. Those events centered primarily

on Williams pleading guilty to federal bribery charges. After Williams resigned

2 Attorney General Kane succeeded Attorney General Corbett as attorney general.

-3- J-A16014-20

from office, First Assistant District Attorney Kathleen Martin (“Acting District

Attorney Martin”) became the acting district attorney by operation of law.

From there, Acting District Attorney Martin disclosed two conflicts of interest

in the case. The first conflict concerned her former law firm representing Ali

in negotiating a cooperation agreement with the Attorney General’s Office.

The second conflict Acting District Attorney Martin revealed was that her

former law firm represented Williams in connection with the federal grand jury

investigation that resulted in his guilty plea and resignation.

Brown filed a pre-trial Motion to disqualify the Philadelphia District

Attorney’s Office and the Dauphin County District Attorney’s Office from

prosecuting the case. In her Motion, Brown asserted that there were disabling

conflicts of interest in the case. Specifically, Brown argued that the

prosecutors from the Philadelphia District Attorney’s Office, whom District

Attorney Marsico appointed as special prosecutors in the case, reported to and

took direction from Acting District Attorney Martin. The trial court granted the

motion in part and denied it in part, disqualifying the special prosecutors from

the Philadelphia District Attorney’s Office, but not the Dauphin County District

Attorney’s Office. Brown filed an interlocutory appeal challenging the trial

court’s decision, and this Court quashed the appeal as premature.

The case proceeded to jury selection. There, the Commonwealth

exercised five peremptory strikes, each one directed against non-white jurors.

In particular, the Commonwealth excluded two black females from the jury.

-4- J-A16014-20

Brown, who is black, objected that the peremptory challenges were

discriminatory and illegal under Batson v. Kentucky, 476 U.S. 79 (1986).

The trial court determined that Brown established a prima facie case of

purposeful discrimination regarding one of the Black jurors. In response, the

Commonwealth proffered race-neutral explanations for striking the juror.

Ultimately, the trial court determined that the Commonwealth lacked

discriminatory intent in striking the Black juror and overruled Brown’s Batson

objection.

Following jury selection, the Commonwealth presented former Chief

Deputy Attorney General Frank Fina (“Fina”) as a trial witness. Fina, who

supervised the sting operation, testified on direct examination about the plea

bargain offered to Ali in return for his work as an undercover confidential

witness. Fina did not testify as to any personal observation of Brown, and he

did not testify as to any facts that, absent the testimony of Ali, were relevant

to Brown’s guilt or innocence. On cross-examination, Brown sought to

confront Fina with pornographic and racist emails that he had exchanged with

colleagues in the Attorney General’s Office. Brown argued that the emails,

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