Com. v. Crimi, M.

CourtSuperior Court of Pennsylvania
DecidedMay 1, 2023
Docket481 MDA 2022
StatusUnpublished

This text of Com. v. Crimi, M. (Com. v. Crimi, 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. Crimi, M., (Pa. Ct. App. 2023).

Opinion

J-S02015-23

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : MICHAEL A. CRIMI : : Appellant : No. 481 MDA 2022

Appeal from the Judgment of Sentence Entered December 2, 2021 In the Court of Common Pleas of Columbia County Criminal Division at No(s): CP-19-CR-0000298-2020

BEFORE: PANELLA, P.J., OLSON, J., and DUBOW, J.

MEMORANDUM BY PANELLA, P.J.: FILED: MAY 1, 2023

Michael Crimi appeals the judgment of sentence imposed by the

Columbia County Court of Common Pleas after a jury convicted him of third-

degree murder and related offenses for beating his then-girlfriend’s three-

year-old daughter, I.B., to death. Crimi raises seven issues on appeal,

including: a challenge to the trial court’s granting of one of his requested

remedies for the Columbia County Clerk of Courts’ (“clerk of courts”)

inadvertent disclosure of ex parte and sealed defense motions to the Columbia

County District Attorney’s office (“DA”); challenges to the trial court’s

discretion in declining to conduct individual voir dire of potential jurors as well

as its discretion in admitting social media posts and testimony by the

Commonwealth’s forensic pathologist into evidence; a sufficiency and a weight

claim; and a discretionary aspect of sentencing claim based in part on the fact J-S02015-23

that he was 19 years old when the offenses occurred. As Crimi’s issues are

either waived or meritless, we affirm.

On November 25, 2017, I.B. was in the care of Crimi, when Crimi called

911 because I.B. was unconscious. I.B. was taken to the hospital and later

died from blunt head trauma. The death was ruled a homicide and Crimi was

charged with the homicide, along with related offenses. The Commonwealth

also filed a notice of its intent to seek the death penalty.

Defense counsel filed several ex parte motions related to expert

witnesses and investigative services, which were placed under seal. However,

the clerk of courts inadvertently disclosed seven of those motions to the DA

and posted them on the public docket. Crimi filed a motion to dismiss based

on this disclosure, seeking to either have his charges dismissed or the death

penalty notice revoked or, in the alternative, have the prosecution of his case

transferred to the Pennsylvania Office of the Attorney General (“OAG”). See

Motion to Dismiss, 8/4/2020, at 7-8 (unpaginated).

The court held a hearing on the motion on September 3, 2020. Following

the submission of briefs, the court issued an order and opinion the following

month. In the opinion, the court found that the title of the motions revealed

defense strategy, and although the disclosure of the ex parte motions had

been inadvertent, the court agreed that the circumstances mandated the

appointment of another prosecutor. See Trial Court Opinion, 10/2/2022, at 3,

7. The court transferred prosecution of the case to the OAG.

-2- J-S02015-23

Crimi filed a motion for reconsideration, which the court denied after

holding a hearing on the motion on November 5, 2020. Two months later, on

January 12, 2021, the court granted the OAG’s motion to withdraw the

intention to seek the death penalty.

The court set a trial date. Prior to the start of jury selection, the court

announced that because this was no longer a capital case, there would not be

individual voir dire. Rather, the court would conduct the voir dire en masse,

and when doing so, would reference the proposed voir dire questions

submitted by the parties. See N.T., 9/24/2021, at 2. The court advised

counsel they would be allowed to ask supplemental questions. See id. at 5.

Jury selection was then conducted and completed on September 30, 2021.

Trial began a few days later, on October 4, 2021. I.B.’s mother, Sierra

Brown, testified the following day. She recounted I.B. was born in

Pennsylvania in 2014 when Brown was in ninth grade, and that I.B.’s father

had never met I.B. See N.T., 10/5/2021, at 465-466. Brown stated she moved

to Florida, and attended a high school for teenage mothers there. See id. at

468, 471. Brown met Crimi while in Florida, and the two began dating in June

2017. See id. at 472.

Brown testified she and I.B. moved back to Pennsylvania in August

2017. See id. at 474. The two of them moved into their own apartment the

following month, in September 2017. See id. at 477. Crimi then moved to

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Pennsylvania, and in with Brown and I.B., in October 2017. See id. at 478-

79.

Brown got a job working four days a week from 7 a.m. until 5:30 p.m.

See id. at 480. Crimi watched I.B. on the days Brown went to work. See id.

at 480. Brown recalled that she got several texts from Crimi about I.B. while

she was in Crimi’s care, and the Commonwealth admitted the texts into

evidence. Brown read several texts which indicated Crimi’s frustration with

caring for I.B. For example, Brown testified that on October 25, 2017, Crimi

sent a text to Brown while she was at work complaining I.B. “won’t stop crying

and I’m going to jump off the balcony.” Id. at 538. He then texted he was

“literally about to go insane today.” Id.

Brown testified she received a text from Crimi a few days later, on

October 28, telling her I.B. had fallen in the tub and hit her head. See id. at

488. When Brown returned home, she saw I.B. had a bruise around her right

eye. See id. at 488-489. Brown testified I.B. also had a bruise on her left

cheek at this time, which Crimi told Brown I.B. had gotten when she had fallen

down the stairs. See id. at 492. Then, on October 29, Crimi sent a message

to Brown telling her he was angry as he believed I.B. was lying to him. See

id. at 542.

In early November 2017, Brown testified I.B. began losing her hair and

vomiting. Brown eventually took I.B. to the emergency room on November

10, where I.B. had a CT scan of her head. I.B. was ultimately diagnosed with

-4- J-S02015-23

constipation and discharged, with Brown being advised to make follow-up

appointments. See id. at 495-498.

Brown testified that I.B.’s vomiting abated but that I.B. became more

and more clingy to Brown, and was wetting her bed despite being potty-

trained. See id. at 494, 497, 499. According to Brown, Crimi would get

frustrated with I.B., and Brown had to tell Crimi not to spank I.B. after seeing

him use that form of punishment on her. See id. at 500.

Brown testified her relationship with Crimi deteriorated between

November 10 and November 25, as the two were arguing more and more.

See id. at 500-501. Brown testified Crimi grew increasingly clingy, see id. at

493, and sent her texts professing his love for her while also relaying his

insecurity about Brown’s feelings for him. See id. at 543-554. She recounted

that she asked Crimi to move out multiple times, but he refused. See id. at

507.

Brown testified she got a call on November 22 from Crimi, who was

watching I.B. Crimi told Brown that I.B. had once again fallen and hit her head

on the bathtub faucet. See id. at 504. I.B. got a bruise around her right eye.

See id. at 505. The following day was Thanksgiving, which Brown, I.B. and

Crimi spent together. Brown testified she again asked Crimi to leave that day,

but he did not. See id. at 505.

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Com. v. Crimi, M., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-crimi-m-pasuperct-2023.