Com. v. Zieglar, D.

2024 Pa. Super. 188
CourtSuperior Court of Pennsylvania
DecidedAugust 21, 2024
Docket515 WDA 2023
StatusPublished
Cited by1 cases

This text of 2024 Pa. Super. 188 (Com. v. Zieglar, D.) 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. Zieglar, D., 2024 Pa. Super. 188 (Pa. Ct. App. 2024).

Opinion

J-A06001-24

2024 PA Super 188

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : DEANGELO ZIEGLAR : No. 515 WDA 2023

Appeal from the Order Entered April 5, 2023 In the Court of Common Pleas of Allegheny County Criminal Division at No(s): CP-02-CR-0002096-2022

BEFORE: LAZARUS, P.J., PANELLA, P.J.E., and BECK, J.

OPINION BY LAZARUS, P.J.: FILED: August 21, 2024

The Commonwealth of Pennsylvania appeals from the order, entered in

the Court of Common Pleas of Allegheny County, denying its request to

impanel a death-qualified jury. After careful review, we reverse and remand

for further proceedings.

On January 19, 2022, police officers responded to a report of a shooting

at the intersection of Lincoln and Sheridan Avenues in Pittsburgh. Upon

arrival, police encountered Rachel Dowden, who had been shot multiple times.

Dowden was transported to Allegheny General Hospital and was pronounced

deceased at 9:18 p.m. that same day. The ensuing police investigation

revealed that Dowden had a final Protection from Abuse (PFA) order against

Appellee Deangelo Zieglar. On October 20, 2022, after additional

investigation not relevant to this appeal, the Commonwealth charged Zieglar J-A06001-24

with multiple offenses, including criminal homicide,1 for the shooting death of

Dowden.

As part of the pre-trial proceedings in this matter, the Commonwealth,

on April 14, 2022, filed a Notice of Intention to Seek Death Penalty and Notice

of Aggravating Circumstances Pursuant to Pa.R.Crim.P. 8022 and 42 Pa.C.S.A.

§ 9711 (hereinafter, “Notice”). In its Notice, the Commonwealth set forth the

following five aggravating circumstances/factors:

1. The victim was a prosecution witness to a murder or other felony committed by [Zieglar] and was killed for the purpose of preventing [her] testimony against [Zieglar] in any grand jury or criminal proceeding involving such offenses. 42 Pa.C.S.[A.] § 9711(d)(5).

2. [Zieglar] committed the killing while in the perpetration of a felony. [Id. at] § [](d)(6).

3. In the commission of the offense[, Zieglar] knowingly created a grave risk of death to another person in addition to [the] homicide victim. [Id. at] § [](d)(7).

4. [Zieglar] has a significant history of felony convictions involving the use or threat of violence to the [victim]. [Id. at] § [](d)(9).

5. At the time of the killing, [Zieglar] was subject to a court order restricting in any way [his] behavior toward the victim pursuant to 23 Pa.C.S.[A.] Ch. 61 or any other order of a court of common

____________________________________________

1 18 Pa.C.S.A. § 2501(a).

2 Rule 802 requires that the Commonwealth notify the defendant, at the time

of arraignment, of any aggravating circumstances the Commonwealth intends to submit at the capital sentencing hearing. See id. Additionally, Rule 802 requires the Commonwealth to list the specific aggravating circumstances as enumerated in section 9711 of the Sentencing Code. See id.

-2- J-A06001-24

pleas or of the minor judiciary designed in whole or in part to protect the victim from [Zieglar]. 42 Pa.C.S.[A.] § 9711(d)(18).

Notice, 4/14/22, at 1-2.

During one of many status conferences, the trial court indicated that it

would sua sponte order a hearing,3 at which it would require the

Commonwealth to prove the aggravating factors set forth in its Notice. See

Order and Opinion, 4/5/23, at 1-2 (detailing case’s procedural history);

Commonwealth’s Motion to Reconsider, 10/31/22, at 1-5 (requesting trial

court reconsider sua sponte decision to hold hearing on death penalty factors).

The Commonwealth filed a motion to reconsider, to which, on November 2,

2022, the trial court ordered Zieglar file a response.

On November 6, 2022, Zieglar filed his response. See Defendant’s

Response to Commonwealth’s Motion to Reconsider Order to Prove

Aggravators of Death Penalty Notice, 11/6/22, at 1-5. In his response, Zieglar

conceded that “under current law it is improper for this Honorable Court to

challenge the Commonwealth’s exercise of discretion in seeking the death

penalty.” Id. at 3. Additionally, Zieglar “raise[d] a claim that the

Commonwealth [was] abusing its discretion in seeking the death penalty

without providing, in evidence, a factual underpinning for each aggravating

factor.” Id. Ultimately, the trial court did not hold an evidentiary hearing

after concluding that “absent a challenge put forth by [Zieglar]’s attorneys,

3 We observe that this order, if it was ever written, does not appear in the

certified record before this Court. However, it is clear from our review, based upon the citations infra, that the trial court did, in fact, order this hearing.

-3- J-A06001-24

this [c]ourt has no authority to order such an evidentiary hearing.” Order and

Opinion, 4/5/23, at 4.

After pre-trial procedure not relevant to the instant appeal, the case

proceeded to voir dire. On March 13, 2023, both parties filed their respective

proposed voir dire questions. See Commonwealth’s Proposed Voir Dire

Questions: Death Penalty, 3/13/23, at 1-9 (unpaginated); Defendant’s

Proposed Voir Dire Questions, 3/13/23, at 4-20. The Commonwealth filed 34

proposed voir dire questions and Zieglar filed 70 proposed voir dire questions.

Both parties’ proposed questions pertained almost exclusively to the death

penalty. See Trial Court Opinion, 6/28/23, at 4-5 (summarizing proposed voir

dire questions). Additionally, we note that Zieglar did not oppose the

Commonwealth’s pursuit of the death penalty at this time.

On April 3, 2023, the trial court conducted a hearing on the parties’

proposed voir dire questions. After argument, the trial court took the matter

under advisement. On April 5, 2023, the trial court issued the following order:

a) the 34 voir dire questions filed by the Commonwealth on March 13, 2023[,] will not be permitted to be used during jury selection in this case;

b) the 70 questions filed by [Zieglar] on March 13, 2023, will not be permitted to be used during jury selection in this case;

c) the jury selection in this case will be limited to determining the ability of each juror to be fair and impartial in deciding the verdict in this case; there will be no deliberations as to sentence;

d) within the next 40 days, counsel for the Commonwealth and counsel for [Zieglar] may submit proposed voir dire questions

-4- J-A06001-24

which do not mention or refer to the death penalty as a possible sentence in this case;

e) after the [c]ourt has received all re-submitted proposed voir dire questions, a status conference will be scheduled within 10 days, to address any outstanding discovery issues and jury selection procedures;

f) the scheduling times set forth above will be stayed should either party timely file a request for appellate review of this Order[.]

Order, 4/5/23, at 1-2 (emphasis added).

Additionally, the trial court attached an opinion explaining its reasoning

for denying the proposed voir dire questions. See Opinion and Order, 4/5/23,

at 1-10. In particular, the trial court considered that Governor Josh Shapiro

had continued then-Governor Tom Wolf’s moratorium on the death penalty4

and found that the moratorium has made it functionally impossible for a jury

to impose the death penalty. See id. at 3-9. Additionally, the trial court

further concluded that, in light of the moratorium, it was compelled to act on

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Related

Com. v. Zieglar, D.
2024 Pa. Super. 188 (Superior Court of Pennsylvania, 2024)

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Bluebook (online)
2024 Pa. Super. 188, Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-zieglar-d-pasuperct-2024.