Commonwealth v. Hunter

60 A.3d 156, 2013 Pa. Super. 7, 2013 WL 150779, 2013 Pa. Super. LEXIS 9
CourtSuperior Court of Pennsylvania
DecidedJanuary 15, 2013
StatusPublished
Cited by11 cases

This text of 60 A.3d 156 (Commonwealth v. Hunter) 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. Hunter, 60 A.3d 156, 2013 Pa. Super. 7, 2013 WL 150779, 2013 Pa. Super. LEXIS 9 (Pa. Ct. App. 2013).

Opinion

OPINION BY

LAZARUS, J.

Michele Renae Hunter appeals from the trial court’s order denying her pretrial motion in limine1 seeking to exclude from evidence text messages (texts)2 sent between her and her co-defendant Husband.3 On appeal, we are faced with determining whether our Commonwealth’s confidential spousal communications privilege, codified at 42 Pa.C.S. § 5914, extends to Hunter’s texts.

Because the record reflects that the texts are being used in ongoing child abuse proceedings involving Hunter and the child-victim in the instant criminal case, Hunter could not have had a reasonable expectation that her communications would remain confidential. Therefore, we agree with the trial court that the section 5914 spousal privilege does not apply under the facts of this case and the texts are admissible at trial. Accordingly, we affirm.

FACTS

In June 2012, Hunter was charged with simple assault (Ml),4 aggravated assault5 (F-l) and endangering the welfare of a child (F-3).6 The four-year-old victim, [158]*158B.H., Jr., is Husband’s biological son and Hunter’s stepson. While in Hunter’s care, B.H., Jr., suffered a severe brain injury (subdural hemorrhage), which led to cardiopulmonary arrest. The attending pediatrician on staff at the hospital where B.H., Jr., was taken for treatment opined that there is a high probability that he will suffer lasting brain damage as a result of the injury.7 The doctor also noticed that B.H., Jr., had bruising over his entire back, consistent with hand prints, as well as on both arms and elbows. The doctor noted that child abuse was suspected.

Initially, Hunter told the police that on March 16, 2011, B.H., Jr., had been upstairs and had fallen and reopened an old cut on his chin. She also told the officers that the boy had passed out in the bathroom, fell, and was non-responsive and had difficulty breathing. Days later, Hunter told the authorities that she had not given accurate information regarding how the child became injured and that, in fact, on March 15, 2011, she had pushed the child down, causing him to hit his head. She said that he became unresponsive and that she was unable to rouse him by carrying him to the bathroom and splashing cold water in his face. She said that the boy remained relatively unresponsive (“limp”) throughout the day, falling in and out of periods of responsiveness. He was unable to move his limbs or sit up on his own.

Hunter also told the authorities that throughout the day on March 15, she began sending Husband texts8 at work, describing the boy’s deteriorating condition over a 36-hour span. B.H., Jr., was unable to walk or sit up on his own that evening and was put to bed by Husband and Hunter, both of whom checked on him throughout the night. The next morning, March 16, B.H., Jr. was able to walk with some assistance, although he continued to exhibit many of the physical symptoms from the day before. That evening, as Husband carried his son into his bedroom, B.H., Jr. began gasping for breath and went into cardiac arrest. He was rushed to the hospital.

Hunter was charged with simple assault, aggravated assault and endangering the welfare of a child; Husband was charged with conspiracy to endanger the welfare of a child and endangering the welfare of a child. On October 17, 2011, Hunter filed an omnibus pretrial motion seeking to exclude from evidence the texts she sent to Husband on March 15th & 16th. The trial court held a hearing on the motion on December 15, 2011. Ultimately the trial court denied Hunter’s motion. This timely appeal follows.

DISCUSSION

This Commonwealth’s statute regarding privileged confidential communications between spouses, which is central to this appeal, states:

Except as otherwise provided in this subchapter, in a criminal proceeding neither husband nor wife shall be competent or permitted to testify to confidential communications made by one to the other, unless this privilege is waived upon the trial.

42 Pa.C.S.A. § 5914 (enacted 1976). As noted, the only recognized exception to [159]*159section 5914’s privilege is when it is waived by the spouse asserting the privilege upon trial. Historically, the privilege was enacted to preserve marital harmony by encouraging free marital communication, allowing spouses to confide freely, and protecting the privacy of marriage. Commonwealth v. McBurrows, 779 A.2d 509 (Pa.Super.2001). For these reasons, the privilege may be invoked even after a marriage has dissolved.9

Practically, it is important that courts recognize that excluding information may not always further the intended goal of a privilege and may, in fact, hinder the prosecution of legal proceedings intended to protect fragile members of society. One such instance is in the prosecution of child abuse cases when the perpetrator(s) involved are spouses and at least one is the parent of the minor child.

Pennsylvania’s Child Protective Services Law (CPSL) recognizes that, in order to further important public policy, privileged communications may need to give way to the prosecution of child abuse. Under the CPSL, confidential communications between spouses are admissible in any proceedings regarding child abuse or the cause of child abuse. 23 Pa.C.S.A. § 6381(c).10 Although not central to its holding, in Commonwealth v. Spetzer, 572 Pa. 17, 813 A.2d 707 (2002), our Supreme Court recognized that:

[T]he CPSL is relevant to the construction of § 5914 in a more subtle and indirect fashion. The Court in [Commonwealth v.] May recognized that the question of what is a “confidential” communication turns in part on the reasonable expectation the declarant has that the communication will remain confidential. [540 Pa. 237] 656 A.2d [1335], 1341-42 [ (1995) ]. Even if it is assumed that § 6381(c) does not act directly to provide a broad child abuse exception to § 5914’s application in criminal proceedings, it certainly affects what a spouse’s “reasonable expectation” of continued confidentiality may be with respect to marital communication that reveal the previous or intended abuse and intimidation of a child.

Id. at 722.

In Spetzer, the Court found that the spousal communications at issue were not confidential based upon the fact that defendant’s “persistent and sadistic statements” concerning his actual and contemplated crimes against his wife and her children “could not be rationally excluded [under the section 5914 privilege] ... as the challenged communications ‘did not arise from the confidence existing between the parties, but the want of it.’ ” Id. at 721. Although in this case neither side claims that Hunter and Husband’s marriage was in a state of disharmony at the time the texts were sent, the Spetzer Court’s commentary on the interplay of the CPSL and section 5914 is instructive to our holding today.

While communications between spouses are presumed to be confidential11 [160]*160under section 5914,

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Bluebook (online)
60 A.3d 156, 2013 Pa. Super. 7, 2013 WL 150779, 2013 Pa. Super. LEXIS 9, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-hunter-pasuperct-2013.