Com. v. Koubidina, E.

CourtSuperior Court of Pennsylvania
DecidedAugust 28, 2014
Docket2273 MDA 2013
StatusUnpublished

This text of Com. v. Koubidina, E. (Com. v. Koubidina, 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. Koubidina, E., (Pa. Ct. App. 2014).

Opinion

J-S40035-14

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA IN THE SUPERIOR COURT OF PENNSYLVANIA Appellee

v.

EYADE KOMADEGA KOUBIDINA

Appellant No. 2273 MDA 2013

Appeal from the Judgment of Sentence July 15, 2013 In the Court of Common Pleas of York County Criminal Division at No(s): CP-67-CR-0006183-2011

BEFORE: BENDER, P.J.E., BOWES, J. and PANELLA, J.

MEMORANDUM BY PANELLA, J.: FILED AUGUST 28, 2014

Appellant, Eyade Komadega Koubidina, appeals from the judgment of

sentence entered on July 15, 2013, in the Court of Common Pleas of York

County. After careful review, we affirm.

On July 10, 2011, at approximately 5:00 PM, the victim, eleven-year-

See N.T., Trial, 4/1/13, at

131-

answered. See id

permitted A.D. to wait for her friends in the living room. Id. A.D. occupied

the time by playing a video game while Koubidina was on the computer. See

id

ups Id., at 133-134. J-S40035-14

Id., at 135. A.D. recalled that she was wearing a strapless dress that

Id. A.D. laid back on the bed and Koubidina was

Id., at 136. A.D. testified that Koubidina pulled her

Id. According to

Id., at 137. A.D. stated

Id.

Id., at 139.

About an hour later, while walking to the grocery store with her

seventeen-year-old cousin, Jeremy McDonald and her younger brother, A.D.

See id., at 139-

mother. See id

Id., at

185. Koubidina denied any wrongdoing. See id

Id., at 186. In

-2- J-S40035-14

the emergency department at the hospital, Natalie Billings, the Sexual

Assault Forensic Examiner (SAFE) nurse practitioner examined A.D. See id.,

swab for DNA. See id., at 198-200. Officer Mike Mendez of the West York

Police Department was dispatched to York Hospital for a report of a sexual

assault victim. See id., at 215. Officer Mendez spoke with the SAFE nurse

and sent the rape kit to the Pennsylvania State Police Crime Lab for analysis.

See id dvocacy Center.

See id

234- -

sample from [Koubidina] Id., at 236.

Koubidina was subsequently charged with one count of aggravated

indecent assault, involuntary deviate sexual intercourse (IDSI), indecent

assault, corruption of minors and unlawful contact with minor (sexual

offenses). Following a jury trial on April 1, 2013, Koubidina was found guilty

on all counts. Thereafter, on July 15, 2013, the trial court sentenced

Koubidina to the mandatory sentence of 10-

IDSI. Counts 1 and 3 merged with the IDSI for sentencing purposes.

probation on Count 4, corruption of minors. Post-sentence motions were

filed and subsequently denied. This timely appeal followed.

On appeal, Koubidina raises the following issue for our review:

-3- J-S40035-14

1. Whether the trial court abused its discretion in permitting testimony of prior consistent statements by the victim for purposes of rehabilitation pursuant to Pa.R.E. 613 when such statements were not used to rebut a claim of recent fabric contradictory trial testimony?

-settled that

[a]dmission of evidence is within the sound discretion of the trial court and will be reversed only where the court clearly abused that discretion. Proper judicial discretion conforms to the law and is based on facts and circumstances before the court. An abuse of discretion is not a mere error of judgment but, rather, involves partiality, prejudice, bias, ill-will, or manifest unreasonableness.

Commonwealth v. Hardy, 918 A.2d 766, 776 (Pa. Super. 2007) (citations

omitted).

In pertinent part, Pa.R.E. 613 provides:

(c) Witness's Prior Consistent Statement to Rehabilitate.

given an opportunity to cross-examine the witness about the statement and the statement is offered to rebut an express or implied charge of:

(1) fabrication, bias, improper influence or motive, or faulty memory and the statement was made before that which has been charged existed or arose; or

(2) having made a prior inconsistent statement, which the witness has denied or explained, and the consistent statement

Pa.R.E. 613(c)(1)-(2).

received for rehabilitation

-4- J-S40035-14

Pa.R.E. 613, Comment

specifically provides in subsection (c)(1) that the consistent statement must

have been made before Id. (emphasis supplied).

Because [prior consistent] statements are hearsay, their use as

testimony is severely limited; and such statements are

testimony is recently fabricated or a result of corrupt motives. Furthermore, evidence of such statements is admissible only in rebuttal and then only for the purpose of showing that that which the witness now testifies to has not been recently fabricated. As a further restriction upon admissibility the statement must have been made at a time before its ultimate effect on the question trying could have been foreseen. In more recent times this court has interpreted this caveat to mean before any corrupt motive has arisen.

If one testifies that they did a certain thing at a given time, they may be challenged that they said something different before. Such is impeachment by prior contradictory statement. Ordinarily, that one has always said the same thing is subsumed in their testimony and need not be buttressed by evidence of prior consistency, unless that consistency, by allegation of recent fabrication is challenged. When challenged, evidence of prior and continued consistency may be offered. Evidence of prior consistency, absent such challenge is not required and is essentially cumulative and repetitious. To regularly allow testimony of prior consistency may easily become a device to merely augment the credibility of witnesses by others.

Commonwealth v. Hutchinson, 556 A.2d 370, 372 (Pa. 1980) (citations

and internal quotation marks omitted).

At the time of trial, at the conclusion of Commonwealth witness

-5- J-S40035-14

under Pa.R.E. 613 on the record. The following exchange took place at

sidebar:

ATTORNEY KOPE: I was just going to ask to approach. I am just going to lodge an objection under Rule 613 of the Rules of Evidence that is for prior consistent statements. I think this is just getting to the point it is just bolstering.

THE COURT: If that is what the evidence is going to be, this is the first evidence that would be - - well, this would be the second evidence of it.

ATTORNEY KOPE: Okay. And then the other.

THE COURT: So why is it objectionable?

ATTORNEY KOPE: Under Rule 613 you are usually not allowed to bring a prior

THE COURT: One moment. Okay, what is the problem?

unless, of course, we are charging her with fabrication?

THE COURT: That is defense of fabrication.

ATTORNEY KOPE: We are conceding that.

THE COURT: What are you conceding? You have not conceding [sic] anything.

ATTORNEY KOPE: We are attacking her fabrication.

THE COURT: You are claiming that she fabricated this story?

ATTORNEY KOPE: Yes.

THE COURT: So I would think that a prior consistent statement corroborating her story would be particularly important and relevant.

ATTORNEY KOPE: We agree it is just the number of them to a point we think it becomes bolstering after putting on some.

-6- J-S40035-14

THE COURT: Do you have theory for opposition that more than one corroboration of a prior

ATTORNEY KOPE: I have no legal authority.

THE COURT: Okay. Overruled.

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

Related

Commonwealth v. Hardy
918 A.2d 766 (Superior Court of Pennsylvania, 2007)
Commonwealth v. Baumhammers
960 A.2d 59 (Supreme Court of Pennsylvania, 2008)
Commonwealth v. Hutchinson
556 A.2d 370 (Supreme Court of Pennsylvania, 1989)
Commonwealth v. Bruce
916 A.2d 657 (Superior Court of Pennsylvania, 2007)

Cite This Page — Counsel Stack

Bluebook (online)
Com. v. Koubidina, E., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-koubidina-e-pasuperct-2014.