Commonwealth v. Capece

17 Pa. D. & C.5th 113
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedOctober 18, 2010
Docketno. 65 of 2007, C.R.
StatusPublished

This text of 17 Pa. D. & C.5th 113 (Commonwealth v. Capece) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Capece, 17 Pa. D. & C.5th 113 (Pa. Super. Ct. 2010).

Opinion

PICCIONE, J,

— Before this court for disposition is the commonwealth’s omnibus pre-trial motion of a motion in limine. The commonwealth requests thatthe court rule on the admissibility of 92 e-mails between defendant Phillip Jerry Capece (hereinafter, “defendant”) and Shana Niglio (hereinafter, “the complainant”). The commonwealth also asks that the court address the admissibility of the defense that defendant’s ex-wife is responsible for the present charges against him.

The background ofthis case is as follows: defendant, who was 65 years old at the time the alleged crimes occurred, was charged with corruption of minors (18 Pa.C.S.A. § 6301(a)) and unlawful contact with a minor (18 Pa. C.S.A. § 6318(a)(1)) after hard copies of approximately one hundred e-mails were found in the mailbox of Audrey Niglio, the mother of the then 16-year-old complainant. The e-mails consisted of a series of messages over a six-month [115]*115period in 2006 between users of one of the complainant’s e-mail addresses and one of defendant’s e-mail addresses. Some of the e-mails contained sexual references and an offer to exchange $50.00 for sexual favors.

At defendant’s trial in July of 2007, approximately 38 of the e-mails were admitted into evidence during the testimony of the complainant without objection from defense counsel. During the following day of trial, defense counsel began objecting to the reading of some of the e-mails that were admitted into evidence. The court overruled defendant’s objection, and the jury ultimately returned a verdict in favor of the commonwealth. On December 3, 2007, defendant appealed to the Superior Court, arguing that this court abused its discretion in admitting the e-mails because no foundation as to the genuineness of the e-mails was established prior to their admission. The Superior Court determined that defendant waived the issue because defense counsel failed to make a timely objection to the admission of the 38 e-mails. As a result, on December 9, 2008, the Superior Court affirmed the judgment of sentence.

Defendant subsequently filed a petition for relief under the Post Conviction Relief Act, arguing, in part, that defense counsel was unconstitutionally ineffective for failing to lodge a timely objection to the authentication of the 38 e-mails. In an opinion dated September 22, 2009, this court stated that “sufficient circumstantial evidence was not presented by the commonwealth to authenticate the 38 e-mails prior to their admission into evidence at trial.” Commonwealth v. Capece, No. 65 of 2007, C.R. (C.P. Lawrence September 22, 2009). As a result, the court granted defendant’s petition, vacated the convictions [116]*116against him, and granted him a new trial.

On November 30, 2009, the commonwealth filed the instant omnibus pre-trial motion of a motion in limine. Hearings were held on March 8, 2010 and May 25, 2010. During the hearings, the commonwealth presented the testimony of the complainant, the complainant’s mother, and corporal John Stepansky of the Pennsylvania State Police in order to lay a proper foundation for and authenticate the 92 e-mails that may be presented at the new trial.

Rule 901 of the Pennsylvania Rules of Evidence states that the “requirement of authentication or identification as a condition precedent to admissibility is satisfied by evidence sufficient to support a finding that the matter in question is what its proponent claims.” Pa.R.E. 901(a). The testimony of a witness with knowledge that a particular matter is what it is claimed to be may satisfy the requirement of authentication. Pa.R.E. 901(b) (1). Circumstantial evidence may also be sufficient to authenticate a document. Commonwealth v. Brooks, 508 A.2d 316, 318 (Pa. Super. 1986). Such circumstantial evidence may include “factors relating to the contents of the writing and the events before and after the execution of the writing.” Id. at 321.

“The courts of this commonwealth have demonstrated the wide variety of types of circumstantial evidence that will enable a proponent to authenticate a writing.” In re F.P., 878 A.2d 91, 94 (Pa. Super. 2005) (citing Brooks, 508 A.2d at 319). For example, in In re F.P., the Superior Court addressed whether a transcript of computerized instant message conversations between the victim of an aggravated [117]*117assault and the appellant was properly authenticated. In re F.P., 878 A.2d at 93. The instantmessage transcript contained threats and accusations by the appellant that corroborated other evidence presented by the commonwealth. Id. The appellant objected to the admission of the instant messages because it was not shown that the appellant sent the messages. Id. In an effort to authenticate the instant message transcript, the commonwealth demonstrated that, during the conversations, the appellant identified himself by his first name, referenced the fact that the victim had approached authorities about the messages, and confirmed the source of the dispute between the appellant and the victim. Id. at 95. In reaching its conclusion, the Superior Court reasoned:

Essentially, appellant would have us create a whole new body of law just to deal with e-mails or instant messages. The argument is that e-mails or text messages are inherently unreliable because of their relative anonymity and the fact that while an electronic message can be traced to a particular computer, it can rarely be connected to a specific author with any certainty. As appellant correctly points out, anybody with the right password can gain access to another’s e-mail account and send a message ostensibly from that person. However, the same uncertainties exist with traditional written documents. A signature can be forged; a letter can be typed on another’s typewriter; distinct letterhead can be copied or stolen. We believe that the e-mail messages and similar forms of electronic communication can properly be authenticated within the existing framework of PaJRJE. 901 and Pennsylvania case law... We see no justification for constructing unique [118]*118rules for admissibility of electronic communications such as instant messages; they are to be evaluated on a case-by-case basis as any other document to determine whether or not there has been an adequate foundational showing of their relevance and authenticity.

Id. at 95-96. Based on the above-mentioned standard, the Superior Court found that the evidence presented by the commonwealth was “clearly sufficient to authenticate the instant message transcripts as having originated from [the defendant].” Id. at 95.

In the case sub judice, the commonwealth presented similar evidence demonstrating that the e-mails sent to the complainant originated from defendant. The complainant testified that she had known defendant through her mother for several years. N.T., 3/8/10, at 6. According to her testimony, the complainant often visited defendant’s home and performed household chores, such as mowing the lawn, for defendant. Id. at 7. During one of these visits, defendant provided the complainant with his e-mail address. Id. at 8.

Although defendant resided with his live-in girlfriend, defendant and the complainant often had the opportunity to spend time alone together. Id.

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Related

Commonwealth v. Brooks
508 A.2d 316 (Supreme Court of Pennsylvania, 1986)
In the Interest of F.P.
878 A.2d 91 (Superior Court of Pennsylvania, 2005)

Cite This Page — Counsel Stack

Bluebook (online)
17 Pa. D. & C.5th 113, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-capece-pactcompllawren-2010.