Commonwealth v. Bracero

396 A.2d 709, 262 Pa. Super. 189
CourtSuperior Court of Pennsylvania
DecidedApril 11, 1979
Docket2386 and 2481
StatusPublished
Cited by10 cases

This text of 396 A.2d 709 (Commonwealth v. Bracero) 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
Commonwealth v. Bracero, 396 A.2d 709, 262 Pa. Super. 189 (Pa. Ct. App. 1979).

Opinions

CERCONE, Judge:

The instant separate appeals, taken on behalf of brothers Frank and Ralph Bracero, raise the question of whether they were denied effective assistance of counsel due to a conflict of interest during their joint trial for aggravated assaults they allegedly perpetrated on Angel and Geraldo Rolon. The relevant facts are as follows:

In April, 1976 an altercation between the Braceros and Rolons arose at a baseball field and resulted in the Rolons being bludgeoned by baseball bats. According to the Rolons the culprits were appellants Ralph and Frank Bracero, and their father Manolin. When appellants were arrested and charged with aggravated assault, they requested that counsel be appointed to defend them. Consequently, the court appointed Mr. Wiley Parker to represent them, and Mr. Parker satisfied himself that no conflict of interest would arise from dual representation of the brothers. The case proceeded to jury trial wherein the Rolons provided the aforementioned testimony concerning the assaults. Both Ralph and Frank Bracero testified on their own behalf and stated that their brother Alfredo and their father Manolin [192]*192were the assailants. The jury chose to believe the Rolons and appellants were convicted.1 Post trial motions were filed and denied and it was approximately one year after appellant’s trial, before Mr. Parker filed a petition for leave to withdraw as counsel for Ralph Bracero. As its basis the petition merely averred:

“A conflict has arisen between the two defendants which precludes your applicant from continuing to represent both of them at the time of sentencing and on appeal.”

There was nothing further in the petition sufficient to indicate the nature of the conflict, nor any indication that it had existed, much less tainted proceedings, previously. However, since the request was simply for leave to withdraw as counsel, the court granted it without further inquiry into the nature and severity of the conflict.2 New counsel was appointed and represented Ralph Bracero during sentencing and in this appeal.

On November 29, 1977 Mr. Parker filed another petition for leave to withdraw, this time as counsel for Frank Bracero, because Frank Bracero wished to challenge Mr. Parker’s effectiveness at trial on appeal. In this regard Mr. Parker informed the court:

[193]*193“I spoke to Mr. Bracero shortly after he was sentenced on this charge and indicated to him some of the facts and circumstances surrounding my discussions with his brother, Ralph, when I represented both of them, and he Frank, indicated to me that he wished to file this application.

Mr. Parker admitted that his conversations with appellants prior to trial had not established a conflict, but argued that the absence of a colloquy on the record negating the possibility of a conflict arising from dual representation required that appellants receive a new trial. Although the court permitted Mr. Parker to withdraw and again appointed new counsel for appeal, nothing further was done concerning the implications of a potential conflict of interest with regard to proceedings already concluded. In sum, the aforementioned averments of Mr. Parker represent the only foundation that appellants assert in support of their claim that they are entitled to a new trial due to a conflict of interest.

Of course, the right to be represented by counsel is guaranteed by the sixth and fourteenth amendments and “contemplates the service of an attorney devoted solely to the interests of his client. The right to such untrammelled and unimpaired assistance applies both prior to trial in considering how to plead, Von Moltke v. Gillies, 332 U.S. 708, 68 S.Ct. 316, 92 L.Ed. 309 (1948), and during trial, Glasser v. United States, 315 U.S. 60, 70, 62 S.Ct. 457, 86 L.Ed. 680 (1942).” United States ex rel. Hart v. Davenport, 478 F.2d 203, 209 (3d Cir. 1973). However, as recently as in Holloway v. Arkansas, 435 U.S. 475, 98 S.Ct. 1173, 55 L.Ed.2d 426 (1978), the Supreme Court of the United States has stated that the principle which emerges from Glasser without ambiguity is that:

“Requiring or permitting a single attorney to represent codefendants, often referred to as joint representation, is not per se violative of constitutional guarantees of effective assistance of counsel. This principle recognizes that in some cases multiple defendants can appropriately be represented by one attorney; indeed, in some cases, cer[194]*194tain advantages might accrue from joint representation. In Mr. Justice Frankfurter’s view: ‘Joint representation is a means of insuring against reciprocal recrimination. A common defense often gives strength against a common attack.’ Glasser v. United States, supra, 315 U.S., at 92, 62 S.Ct., at 475 (dissenting).” Holloway v. Arkansas, supra, 98 S.Ct. at 1178.

In Pennsylvania the courts have followed this principle, and have added guidelines for determining when a conflict of interest has arisen sufficient to vitiate the proceedings. In order to receive a new trial based upon a conflict of interest, appellants must show that a conflict of interest arose and actually existed during the trial, and that the conflict was of a type which created a potential of harm with regard to the accused’s defense. Commonwealth v. Breaker, 456 Pa. 341, 344-45, 318 A.2d 354 (1974). Of course, if the accused can show that he had a defense inconsistent with that advanced by his co-defendant, or that counsel neglected his case to give a more spirited defense to a co-defendant, he satisfies the aforementioned criteria. Id. See also Commonwealth v. Cox, 441 Pa. 64, 270 A.2d 207 (1970). On the other hand, courts have generally found that no conflict of interest exists where co-defendants receiving joint representation present a joint defense, as by denying culpability and blaming other persons for the crimes. Commonwealth v. Small, 434 Pa. 497, 254 A.2d 509 (1969); Commonwealth v. Resinger, 432 Pa. 398, 248 A.2d 55 (1968); Annot., 34 A.L.R.3d 470 (1970). The difficulty with appellants’ claims of conflict of interest and ineffective assistance of counsel in the instant case is that they fall precisely into this last category. Both appellants testified at trial that it was a third brother and their father, rather than they, who inflicted the beatings upon the Rolons. Once again in Mr. Justice Frankfurter’s words in Glasser v. United States, supra: “A common defense often gives strength against a common attack.”

Of course, something manifestly occurred after trial in the instant case which caused Mr. Parker to conclude that a [195]*195conflict of interest “has arisen,” but the record itself supports the conclusion that the conflict did not arise prior to or during trial, and that Mr. Parker gave both appellants an equally spirited defense. Mr.

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Bluebook (online)
396 A.2d 709, 262 Pa. Super. 189, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-bracero-pasuperct-1979.