Commonwealth v. Hyatt

584 A.2d 956, 401 Pa. Super. 14, 1990 Pa. Super. LEXIS 3399
CourtSuperior Court of Pennsylvania
DecidedDecember 14, 1990
Docket1904
StatusPublished
Cited by4 cases

This text of 584 A.2d 956 (Commonwealth v. Hyatt) 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. Hyatt, 584 A.2d 956, 401 Pa. Super. 14, 1990 Pa. Super. LEXIS 3399 (Pa. Ct. App. 1990).

Opinions

CIRILLO, President Judge:

This is an appeal from a judgment of sentence entered in the Court of Common Pleas of Allegheny County against appellant, James E. Hyatt. Following a jury trial, Hyatt was convicted of one count of rape. He filed timely post-trial motions which were denied and thereafter the court imposed sentence. In this appeal, Hyatt raises ten issues for our consideration:

1. Did the trial court err in failing to suppress evidence seized from defendant’s vehicle without a search warrant?
[16]*162. Did the trial court err in failing to suppress evidence seized from defendant’s person, without a warrant and without defendant’s voluntary consent?
3. Did the trial court err in sua sponte giving a jury instruction on evidence of flight by defendant?
4. Did the trial court err in failing to instruct the jury on evidence of other crimes or improper conduct by defendant?
5. Did the trial court err in quashing defendant’s subpoena duces tecum to Pittsburgh Action Against Rape?
6. Did the trial court err in denying a new trial where the verdict was inconsistent?
7. Did the trial court err in disallowing defense cross examination of the alleged victim concerning surgery which she underwent prior to the alleged crime?
8. Did the trial court err in denying examination of alleged victim regarding bias or motivation?
9. Did the trial court err in refusing to grant defendant’s request for jury voir dire?
10. Did the trial court err in failing to grant defendant’s demurrer to Commonwealth’s case in chief?

Upon review, we conclude that Hyatt’s fifth claim is meritorious and requires vacatur of his judgment of sentence. Therefore, we address only that issue.

Hyatt claims that the trial court erroneously quashed his subpoena duces tecum which he served upon Pittsburgh Action Against Rape (“PAAR”), the rape crisis center where the rape victim received counselling. The subpoena directed PAAR to produce its file concerning the rape victim. Hyatt claims that he served the subpoena so that PAAR would produce in court “any and all of its records in its possession for examination by the court to discern if any exculpatory material may have been contained therein.” PAAR refused to accept the subpoena and made an oral motion to quash the subpoena at a hearing before the Honorable Jeffrey A. Manning. At the hearing, Hyatt was permitted to question Molly Knox, the director of PAAR, only about the type of information usually maintained in [17]*17PAAR file; he was not permitted to question Knox with respect to any specific information contained in the victim’s records. Subsequently, the trial court granted PAAR’s motion to quash.

In its opinion in support of its decision to grant the motion to quash, the trial court stated that it had heard testimony from Knox regarding the information routinely developed by PAAR during its counselling sessions. The court stated, “no substantially verbatim statements by the victim exist or are maintained by PAAR; nor does any material exist which could be considered as such; nor does the victim adopt as her own, any information written or recorded by PAAR’s sexual assault counselors.” The trial court concluded that the information contained in the files could not be deemed material evidence under Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963). Therefore, the trial court reasoned, it was unnecessary to conduct an in camera review of the victim’s PAAR records.

Hyatt claims that it was erroneous for the trial court to refuse to conduct an in camera review of the file and for the trial court to preclude him from reviewing, or questioning Knox about, the victim’s file. Hyatt contends that the trial court’s actions contravene the mandates of Commonwealth v. Wilson, 375 Pa.Super. 580, 544 A.2d 1381 (1988), alloc. granted, 525 Pa. 582, 575 A.2d 113 (1990).1 We agree.

The facts in Wilson are remarkably similar to those in the case at bar. Wilson was convicted of the rape and indecent assault of a woman. The day after the assault the [18]*18victim went to Alice Paul House (“APH”), a rape crisis center, and was interviewed by staff members. Prior to trial, Wilson served a subpoena duces tecum on the director of APH, requesting production of their records. APH filed a petition to quash the subpoena, stating that the records were confidential pursuant to 42 Pa.C.S. § 5945.1. The trial court granted APH’s motion.

On appeal, Wilson claimed that section 5945.1 was inapplicable and, in the alternative, if it was applicable it was unconstitutional. We examined our supreme court’s decision in In the Matter of Pittsburgh Action Against Rape, 494 Pa. 15, 428 A.2d 126 (1981), a case decided prior to the enactment of section 5945.1, in which the court refused to create an absolute privilege of confidentiality for communications between a rape counselor and victims seeking aid. Id., 494 Pa. at 26, 428 A.2d at 131. The court, in In the Matter of Pittsburgh, stated that

upon defense request a court should authorize defense inspection of only those statements of the complainant contained in the file which bear upon the facts of the alleged offense. The court, however, must not permit defense inspection of statements having no bearing on the facts of the counselling services PAAR provides. The trial court shall not permit defense review of any other aspect of the file.

In the Matter of Pittsburgh, 494 Pa. at 19, 428 A.2d at 127-28 (emphasis added).2 We noted that our supreme [19]*19court in In the Matter of Pittsburgh also required the trial court conduct its review of the PAAR file in camera so that “... only those statements of the complainant, and not interpretations or recollections of the PAAR counsellor, are to be made available.” Id., 494 Pa. at 28, 428 A.2d at 132. The court limited the term “statements” to include only “verbatim accounts of the complainant’s declarations and notes that the complainant has approved as accurately reflecting what she said.” Id., 494 Pa. at 28, 428 A.2d at 132.

In Wilson, we further cautioned that only statements having a direct bearing to the facts of the alleged offense may be released, and not those relating to counselling services. Wilson, 375 Pa.Super. at 583, 544 A.2d at 1383. Prior to reaching our conclusion in Wilson, we noted that section 5945.1 grants sexual assault counselors a privilege “not to be examined as a witness in any civil or criminal proceeding without prior written consent of the victim being counselled.” Id., 375 Pa.Superior Ct. at 583, 544 A.2d at 1383; see 42 Pa.S.C. § 5945.1. We then concluded that section 5945.1 was inapplicable to the facts in Wilson

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Related

Commonwealth v. Gibbs
642 A.2d 1132 (Superior Court of Pennsylvania, 1994)
Commonwealth v. Hyatt
617 A.2d 1271 (Supreme Court of Pennsylvania, 1993)
Commonwealth v. Miller
593 A.2d 1308 (Superior Court of Pennsylvania, 1991)
Commonwealth v. Hyatt
584 A.2d 956 (Superior Court of Pennsylvania, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
584 A.2d 956, 401 Pa. Super. 14, 1990 Pa. Super. LEXIS 3399, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-hyatt-pasuperct-1990.