Commonwealth v. Rhodes

14 Pa. D. & C.5th 179
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedJuly 20, 2010
Docketno. 628
StatusPublished

This text of 14 Pa. D. & C.5th 179 (Commonwealth v. Rhodes) 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. Rhodes, 14 Pa. D. & C.5th 179 (Pa. Super. Ct. 2010).

Opinion

HODGE, J.,

In the instant matter Ericka Rhodes, defendant, has filed a concise statement of errors complained of on appeal in accordance with Pa.R.A.R 1925(b) which alleges that the trial court committed the following errors: (1) the trial court erred as a matter of law in allowing the jury to determine the question of whether there was a lawful arrest of the defendant; (2) the trial court erred in allowing the Commonwealth to amend the charge of criminal mischief; (3) the trial court erred in allowing the Commonwealth to present an additional witness, Mr. Phil Fava; and (4) the trial court erred in sentencing the defendant pursuant to aggravated guidelines.

The facts of this case can be properly summarized by the following: On May 23,2009, the New Castle Police Department was directed by the Northwest Regional Police to assist in locating a red Dodge that was believed to be located in the vicinity of Court Street, New Castle, Pennsylvania. Officer Justin Houle spotted the red Dodge within that area and followed the vehicle until it pulled over at 709 Countyline Street. Officer Quahliero was also in the area; he arrived at 709 Countyline Street within moments.

Four passengers were seated in the Dodge, including the defendant, Ericka Rhodes, who was in the front passenger seat. Other individuals in the Dodge included a female driver, the defendant’s 14-year-old brother and the defendant’s infant, both positioned in the back seat. Before either officer had an opportunity to approach the vehicle, Defendant exited the Dodge and headed toward the police vehicles. Officer Houk instructed the defendant to get back into the Dodge; defendant physically com[182]*182plied, although she was verbally defiant throughout the process. Officer Quahliero spoke with two women in the front seat of the Dodge and then instructed the defendant to exit the vehicle; after Officer Quahliero identified her, he told the defendant to sit on a nearby curb.

While the defendant was seated on the curb, Officer Houle had to inform her several times to remain quiet. Shortly thereafter, Officer Quahliero instructed Officer Houle to place the defendant under arrest for charges that are not put before the court at this time. As Officer Houle moved toward the defendant to place her under arrest, the defendant began arguing and threw a wallet and cell phone at Officer Houle. Officer Houle was physically struck by these items. The defendant continued to fight with both of the officers to the degree that they had to take her to the ground so that an arrest could be effectuated. The defendant was then placed into custody and seated in the back of a New Castle patrol car. The defendant kicked out the window of the patrol car, shattering the glass and causing it to disperse over the area; she subsequently leaned out of the window and spit on Officer Quahliero. The defendant was later taken to the New Castle Police Department.

New Castle police charged the defendant with one count of assault by prisoner (18 Pa.C.S. §2703(A)), one count of resisting arrest (18 Pa.C.S. §5104), and one count of criminal mischief (18 Pa.C.S. §3304(A)(5)). The charges were later reduced by the district attorney to include only one count of resisting arrest (18 Pa.C.S. §5104), and one count of criminal mischief (18 Pa.C.S. §3304(A)(5)). The defendant was tried by a jury on March 18, 2010 and found guilty of resisting arrest and [183]*183criminal mischief. Sentencing took place on April 29, 2010. Defendant subsequently filed a timely appeal.

Defendant first contends that this court erred in allowing a jury to determine whether or not the police made a lawful arrest on the afternoon of May 23, 2009. The court interprets defendant’s first error complained of to contend that there was insufficient evidence to allow a jury to make a determination of whether or not the defendant could be found guilty of resisting arrest. A review of the record indicates that this issue was not timely presented in pretrial motions nor was it presented in the course of the trial. As such defendant is precluded from asserting the issue on appeal. Pa.R.A.P. 302(a); See e.g., Commonwealth v. Harper, 292 Pa. Super. 192, 436 A.2d 1217(1981).

Defendant next suggests that the Commonwealth was improperly allowed to amend the charge of criminal mischief. A review of the record indicates that no such amendment was made, and defendant’s complaint is therefore without warrant. However, this court would like to take note of Pa.R.C.P. 109, which states that:

“A defendant shall not be discharged nor shall a case be dismissed because of a defect in the form or content of a complaint, citation, summons, or warrant, or a defect in the procedures of these rules, unless the defendant raises the defect before the conclusion of the trial in a summary case or before the conclusion of the preliminary hearing in a court ease, and the defect is prejudicial to the rights of the defendant.”

If a defendant does not raise a defect at the summary trial or before the conclusion of the preliminary hearing, [184]*184the defendant cannot thereafter raise the defect as grounds for dismissal or discharge at a later stage in the proceedings. See Commonwealth v. Krall, 452 Pa. 215, 304 A.2d 488 (1973).

The defendant further claims that the court erred in permitting Phil Fava to testify on behalf of the Commonwealth because the Commonwealth did not disclose his identity at any time prior to Mr. Fava being called to testify.

Pretrial discovery is governed by Pa.R.Crim.P. 573, which provides the court with the discretion to order the Commonwealth, upon motion by the defendant, to allow defense counsel to review items that are material to the preparation of a defense including the names and addresses of witnesses. Pa.R.Crim.P. 573 (D) states:

“(D) Continuing Duty to Disclose. If, prior to or during trial, either party discovers additional evidence or material previously requested or ordered to be disclosed by it, which is subject to discovery or inspection under this rule, or the identity of an additional witness or witnesses, such party shall promptly notify the opposing party or the court of the additional evidence, material or witness.”

This rule also establishes a remedy for any failure to timely provide discovery items in Pa.R.Crim.P. 573(E), which states:

“(E) Remedy. If at any time during the course of proceedings it is brought to the attention of the court that a party has failed to comply with this rule, the court may order such party to permit discovery or inspection, may [185]*185grant a continuance, or may prohibit such party from introducing evidence not disclosed, other than testimony of the defendant, or it may enter such order as it deems just under the circumstances.”

Pennsylvania courts have addressed similar circumstances regarding untimely disclosure of witnesses. It is apparent that a trial court has broad discretion over the appropriate sanction to remedy a violation of Pa.R.Crim.P. 573. Commonwealth v. Gordon, 364 Pa. Super. 521, 540, 528 A.2d 631, 641 (1987). In Gordon, the Commonwealth failed to disclose the existence of a police report in response to a pretrial request.

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Related

Commonwealth v. Jones
668 A.2d 491 (Supreme Court of Pennsylvania, 1995)
Commonwealth v. Rines
372 A.2d 901 (Superior Court of Pennsylvania, 1977)
Commonwealth v. Harper
436 A.2d 1217 (Superior Court of Pennsylvania, 1981)
Commonwealth v. COOPER
362 A.2d 1041 (Superior Court of Pennsylvania, 1976)
Commonwealth v. Walls
926 A.2d 957 (Supreme Court of Pennsylvania, 2007)
Commonwealth v. Eicher
605 A.2d 337 (Superior Court of Pennsylvania, 1992)
Commonwealth v. Gordon
528 A.2d 631 (Supreme Court of Pennsylvania, 1987)
Commonwealth v. Krall
304 A.2d 488 (Supreme Court of Pennsylvania, 1973)
Commonwealth v. Colson
490 A.2d 811 (Supreme Court of Pennsylvania, 1985)
Commonwealth v. Grimm
378 A.2d 377 (Superior Court of Pennsylvania, 1977)
Commonwealth v. Crossley
653 A.2d 1288 (Superior Court of Pennsylvania, 1995)

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Bluebook (online)
14 Pa. D. & C.5th 179, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-rhodes-pactcompllawren-2010.