Com. v. Eaddy, A.

CourtSuperior Court of Pennsylvania
DecidedFebruary 26, 2025
Docket738 EDA 2024
StatusUnpublished

This text of Com. v. Eaddy, A. (Com. v. Eaddy, A.) 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. Eaddy, A., (Pa. Ct. App. 2025).

Opinion

J-S31005-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : AUSTIN EADDY : : Appellant : No. 738 EDA 2024

Appeal from the PCRA Order Entered February 7, 2024 In the Court of Common Pleas of Chester County Criminal Division at No(s): CP-15-CR-0001537-2016

BEFORE: BOWES, J., McLAUGHLIN, J., and BECK, J.

MEMORANDUM BY BOWES, J.: FILED FEBRUARY 26, 2025

Austin Eaddy appeals from the order that dismissed his petition filed

pursuant to the Post Conviction Relief Act (“PCRA”). We affirm in part, vacate

in part, and remand for further proceedings.

Appellant is serving a sentence of four to ten years of imprisonment for

convictions of attempted rape and indecent assault. We summarized the facts

and procedure of the case as follows on his direct appeal, and reproduce it

here at length due to their relevance to the issues we address infra:

The Commonwealth alleged Appellant took the complainant’s phone and sexually assaulted her in a parking garage at West Chester University. Appellant and the complainant were both students at the university, but did not know each other before the incident in question. Appellant and the complainant admitted drinking alcohol at separate parties before meeting.

Surveillance video showed Appellant and the complainant meeting on the street at approximately 2:00 a.m. on April 1, 2016. They walked across campus together and eventually entered a parking J-S31005-24

garage through a window in the concrete wall. Once inside the parking garage, the complainant handed Appellant a phone, and [he] put the phone in his pocket. Shortly thereafter, Appellant and the complainant embraced near a set of garage doors, which were closed at the time. The video showed the two apparently embracing, kissing, and engaging in other intimacies by the garage doors. Appellant and the complainant then walked from the garage doors to a space between two parked cars. As discussed below, Appellant and the complainant provided different accounts of what happened between the two cars.

An independent witness, Catherine Doherty, entered the parking garage. She could not recall where she parked and was pressing the button on her key fob. She then heard a distressed female voice asking for her phone. According to Ms. Doherty, she saw Appellant standing in front of the complainant. The complainant was on her back on top of the hood of a car, and the complainant’s pants were down. When Ms. Doherty asked what was going on, Appellant stated, “Oh shit,” and ran. The complainant left in a different direction than Appellant and was crying and pulling up her pants. Ms. Doherty initially pursued Appellant, but [he] exited the parking garage through the window in the concrete wall.

Ms. Doherty then caught up with the complainant. Ms. Doherty did not know the complainant before the incident, but learned that they both lived in the same residence hall. Ms. Doherty walked with the complainant to the residence hall and opened the door for her. A security guard noticed that the complainant’s knee was bleeding and called West Chester University police. Although the complainant initially stated that she wanted to go to her room, [she] then told the guard she was sexually assaulted.

Officer Matthew Rychlak responded to the dispatch based on the security guard’s initial call. As the officer was parking his car by the residence hall, he received an update that the complainant also reported a sexual assault. The officer entered the residence hall and initially attempted to interview the complainant in a common room of the residence hall. However, he then had Ms. Doherty enter the room and interviewed the complainant with Ms. Doherty present. The officer indicated that the complainant appeared more comfortable with Ms. Doherty present.

During this interview, the complainant told the officer she was sexually assaulted. [She] initially reported she was in the parking

-2- J-S31005-24

garage when a black male approached her and forced her to engage in oral and vaginal intercourse.

An ambulance took the complainant to a hospital where she underwent a sexual assault examination. Ms. Doherty accompanied [her] to the hospital. A blood test revealed that the complainant’s blood-alcohol concentration was over .20%. The sexual assault examination did not detect the presence of Appellant’s DNA on the complainant. Officer Rychlak separately interviewed Ms. Doherty at the hospital, and she told the officer that she witnessed a rape.

....

Appellant, who had left the campus sometime after the incident, was taken into custody on April 6, 2016. The Commonwealth subsequently filed an information charging Appellant with rape, attempted rape, indecent assault, and theft, among other offenses.

Appellant retained counsel and submitted numerous pretrial motions seeking discovery and the admission of evidence regarding the complainant . . . and Ms. Doherty. On June 12, 2017, the Commonwealth filed a motion in limine to preclude Appellant from referring to . . . the complainant’s prior sexual conduct, including her text messages to third parties . . . and [also] Ms. Doherty’s previous sexual assault.

On June 19, 2017, the trial court held a hearing on the Commonwealth’s motion in limine. The trial court heard [the] parties’ general arguments discussing the bases of the motion in general terms. . . . The trial court scheduled an in camera conference, with a court reporter present, for June 23, 2017, to hear arguments based on more specific facts.

On July 10, 2017, the trial court entered an order granting the Commonwealth’s motion in limine. The trial court, in a footnote to its order, reasoned that (1) the Rape Shield Law, 18 Pa.C.S. § 3104, precluded Appellant from presenting the complainant’s text messages regarding her “sexual proclivities,” . . . and (3) the evidence of a previous sexual assault against Ms. Doherty w[as] irrelevant and any relevant purpose would be outweighed by the potential for prejudice. The docket and record contained no indication that the trial court held a formal in camera hearing.

-3- J-S31005-24

However, the trial court later referred to “off the record” proffers made by Appellant.

At trial, the complainant testified that she had been drinking at several parties before she met Appellant. [She] stated she could not recall the events after the last party that she attended. Specifically, the complainant testified that she did not remember meeting Appellant on the street, walking with him to the parking garage, or entering the parking garage. She could not explain why she appeared to hand Appellant a phone after they entered the garage. She also could not remember her interactions with Appellant while they were by the garage doors.

According to the complainant, she first recalled being with Appellant when they were between the two cars in the parking lot and Appellant told her “to suck his dick.” Appellant pushed her head down, and when she tried to stop, Appellant pushed her aside and choked her. [She] testified that Appellant had his penis in her mouth. Appellant eventually made her get up and get face down on the hood of the car. [She] could not remember how Appellant had her phone, but recalled asking him to give back her phone. Appellant did not return her phone. Instead, she felt Appellant’s penis at her “butt.” [She] then heard a female, Ms. Doherty, call out. The complainant pulled up her pants and left.

The complainant verified that her phone was later found outside the garage. However, when the phone was returned to her, the screen was shattered. She testified that the screen of the phone was not damaged when she last remembered using the phone.

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Bluebook (online)
Com. v. Eaddy, A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-eaddy-a-pasuperct-2025.