Commonwealth v. Britton

482 A.2d 1294, 334 Pa. Super. 203
CourtSupreme Court of Pennsylvania
DecidedFebruary 14, 1985
Docket744
StatusPublished
Cited by26 cases

This text of 482 A.2d 1294 (Commonwealth v. Britton) is published on Counsel Stack Legal Research, covering Supreme 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. Britton, 482 A.2d 1294, 334 Pa. Super. 203 (Pa. 1985).

Opinions

BECK, Judge:

Appellant was convicted of rape, robbery, burglary, and simple assault.1 His post verdict motions were denied and he was sentenced to ten to twenty years for rape, ten to twenty years for robbery, and ten to twenty years for burglary, to be served consecutively. Sentence was suspended on the simple assault bill. His direct appeal from [208]*208the judgment of sentence is now before this court. We affirm the judgment of the trial court.2

The Commonwealth produced evidence at trial that appellant entered the home of the victim, punched and robbed her, and forced her to submit to sexual intercourse. The appellant’s defense was based on misidentification and alibi.

Among other challenges to the conduct of the trial, appellant contends that the trial judge assumed the role of advocate for the Commonwealth. He asserts that the judge’s extensive and biased questioning of witnesses exhibited prejudice against him and denied him a fair trial. We disagree.

The standards guiding a judge in interrogating witnesses during trial are well established. Our Supreme Court in Commonwealth v. Myma, 278 Pa. 505, 507-508, 123 A. 486, 487 (1924) ruled:

A judge in a jury trial has a right to interrogate witnesses. It sometimes becomes his duty to do so, even to the point of recalling a witness to supply an omission of proof on a material point: Boggs v. Jewell Tea Co., 266 Pa. 428, 434 [106 A. 781]; State v. Jackson, 87 S.C. 407, 69 S.E. 883; Lycan v. People, 107 Ill. 423. But a judge may so conduct an examination as to make it an abuse of discretion, requiring a new trial.
Witnesses should be interrogated by the judge only when he conceives the interest of justice so requires. It is better to permit counsel to bring out the evidence and clear up disputed points on cross-examination unaided by the court; but where an important fact is indefinite or a disputed point needs to be clarified, the court may see that it is done by taking part in the examination ... Judges should refrain from extended examination of witnesses; they should not, during the trial, indicate an opinion on the merits, a doubt as to the witnesses’s credibility, or do anything to indicate a leaning to one side [209]*209or the other, without explaining to the jury that all these matters are for them.

Accord, Commonwealth v. Seabrook, 475 Pa. 38, 379 A.2d 564 (1977); Commonwealth v. Brown, 438 Pa. 52, 265 A.2d 101 (1970); Commonwealth v. Rhem, 283 Pa.Super. 565, 424 A.2d 1345 (1980); Commonwealth v. Toombs, 269 Pa. Super. 256, 409 A.2d 876 (1979).

The American Bar Association’s Standards Relating to the Function of the Trial Judge have further elucidated the role of the judge as interrogator.

[I]t is appropriate for him [the trial judge] from time to time to intervene in the conduct of the case. Thus, when it clearly appears to him that for one reason or another the case is not being presented intelligibly to the jury, the judge is not required to remain silent. On the contrary, he may be question to a witness elicit relevant and important facts. He may interrogate a witness after a cross-examination which appears to be misleading to the jury---- The judge should be aware that there may be greater risk of prejudice from over-intervention than from under-intervention. While he should not hesitate to exercise his authority when necessary, he should avoid trying the case for the lawyers. American Bar Association Project on Standards for Criminal Justice, Standards Relating to the Function of the Trial Judge, Approved Draft, 1972, Commentary, Section 1.1(a), P. 26-27. See: Commonwealth v. Seabrook, supra [475 Pa.] at 45, [379 A.2d at] 567.

Although the standard in these cases is well-settled, its application on appellate review is difficult because the appellate court applies the standard on a cold record.

It is impossible to record the demeanor of the judge when questions are asked by him. A hostile form of mind cannot be recorded unless the questions themselves disclose it; it is impossible to note either the inflection of the voice, the manner of the questioner, or what is generally termed the “atmosphere” of the trial.
[210]*210Commonwealth v. Myma, supra, 278 Pa. at 510, 123 A. at 487.

In order to determine if the trial judge abused his discretion we have carefully evaluated the entire record with particular emphasis on the court’s participation in questioning witnesses.

Initially, we note that the judge’s opening remarks properly instructed the jury as to their role in the case; i.e. the jurors are the sole judge of the facts N.T. 52-53, and the credibility of witnesses, N.T. 54, 59. He specifically cautioned:

Now, I may question some of the witnesses myself during the course of the trial. The questions, if I do ask them, will not reflect any opinion on my part about the evidence or about the case. My only purpose would be to inquire into matters which have not been fully explored, or matters that I think need some clarification.
Again, a cautionary instruction to you, do not look to me to fill in all the little details of the case. That is not my role. I will only get involved in the questioning if it is something that I feel has not been fully explored and that is a proper area for me to get into or matters that require clarification.
N.T. 60-61.

The court repeated this cautionary instruction before questioning the victim and the appellant during the trial. N.T. 165, 446.

In its charge to the jury the court again acknowledged its limited role and the jury’s proper role. The court reminded the jury:

Again, as I said, it is your recollection of the evidence, ladies and gentlemen, both the direct and the circumstantial evidence and not mine or the lawyers on which you rely during your deliberations.
You are not bound by any opinion you might think the lawyers or I have expressed concerning the guilt or innocence, credibility of witnesses, weight of . evidence, [211]*211facts proven by the evidence or inferences to be drawn from the facts.
N.T. 602.

In a four hundred and eighty seven page trial transcript, only a small portion, twelve pages, included questions that the court posed relating to police practices. The court directed questions at certain police officers to clarify police practices for the jury. The judge asked one police officer to define the term a “forty-eight”, N.T. 250; others to explain standard line-up procedures. N.T. 307, 316 and 401. The judge queried an investigating officer who had taken night-time photographs of the scene about the lighting conditions that existed when he took them. N.T. 268-269. The judge conducted this questioning in a neutral unbiased manner and clarified the subject matter under consideration.

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Bluebook (online)
482 A.2d 1294, 334 Pa. Super. 203, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-britton-pa-1985.