Commonwealth v. Walker, H., Aplt.

CourtSupreme Court of Pennsylvania
DecidedAugust 19, 2025
Docket13 WAP 2024
StatusPublished

This text of Commonwealth v. Walker, H., Aplt. (Commonwealth v. Walker, H., Aplt.) 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. Walker, H., Aplt., (Pa. 2025).

Opinion

[J-93-2024] IN THE SUPREME COURT OF PENNSYLVANIA WESTERN DISTRICT

TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ.

COMMONWEALTH OF PENNSYLVANIA, : No. 13 WAP 2024 : Appellee : Appeal from the Order of the : Superior Court entered October 13, : 2023, at No. 376 WDA 2022, v. : affirming the Judgment of Sentence : of the Court of Common Pleas of : Allegheny County entered February HAROLD WALKER, : 11, 2022, at No. CP-02-CR- : 0007381-2019. Appellant : : ARGUED: November 20, 2024

OPINION

CHIEF JUSTICE TODD DECIDED: AUGUST 19, 2025 In this appeal by allowance, we consider whether the trial court erred in permitting

the Commonwealth to ask potential jurors during voir dire whether they would be able to

follow the legal principle that the testimony of an alleged victim alone, if believed, is

sufficient proof upon which to find a defendant guilty of sexual assault beyond a

reasonable doubt. For the reasons that follow, we hold that the trial court did not err in

permitting the Commonwealth to pose that question during voir dire in the instant case,

and, thus, we affirm Appellant Harold Walker’s judgment of sentence.

According to the evidence introduced at trial, in 2013, M.W. (“Victim”) lived with

her mother (“Mother”) and infant sister. Appellant, Mother’s boyfriend at the time,

occasionally would babysit Victim and her sister at night when Mother was at work. Victim

testified that, beginning when she was 10 years old, Appellant would enter her bedroom approximately every other night, remove her underwear, and insert his penis into her

vagina. When Victim was 12 years old, she told Mother and both of her grandmothers

what Appellant was doing. Victim testified that Mother did not believe her and became

angry, and that Victim then began to act out physically, punching and breaking things,

and engaging in self-harm (cutting). At some point, Victim also told her doctor, who tested

her for sexually transmitted infections; Victim tested positive. When Victim was 16 years

old, she also disclosed the abuse to one of her teachers, who contacted the police.

In August 2019, Appellant was charged with Rape of a Child,1 Statutory Sexual

Assault (11 years or older),2 Unlawful Contact with a Minor – Sexual Offenses,3 Sexual

Assault,4 Indecent Assault of Person Less than 13 Years of Age,5 Endangering the

Welfare of Children,6 and Corruption of Minors.7 Relevant to the instant appeal, on July

22, 2021, prior to trial, the Commonwealth submitted proposed voir dire questions to the

trial court, including the following:

Under Pennsylvania law, the testimony of the alleged victim standing alone, if believed by you, is sufficient proof upon which to find the defendant guilty in a sexual assault case. Thus, you may find the defendant guilty if the testimony of the alleged victim convinces you beyond a reasonable doubt that the defendant is guilty. Would you be able to follow this principle of law? Commonwealth v. Walker, 305 A.3d 12, 16 (Pa. Super. 2023).8

1 18 Pa.C.S. § 3121(c). 2 Id. § 3122.1(b). 3 Id. § 6318(a)(1). 4 Id. § 3124.1. 5 Id. § 3126(a)(7). 6 Id. § 4304(a)(1). 7 Id. § 6301(a)(1)(ii). 8 The Superior Court observed that, although the certified record in the instant case does

not contain a transcript of the voir dire proceedings, the Commonwealth did not dispute that the question was asked, nor did it argue that Appellant failed to raise a timely objection. Walker, 305 A.3d at 16 n.1. Thus, the court proceeded under the assumption (continued…)

[J-93-2024] - 2 Appellant filed a motion objecting to the proposed voir dire question, which the trial

court denied. Ultimately, the jury convicted Appellant of all charges, and the trial court

sentenced him to an aggregate term of 30½ to 61 years incarceration, followed by 3 years

probation. Following the denial of his post-sentence motion, Appellant appealed to the

Superior Court, alleging that, in addition to imposing a manifestly excessive sentence, the

trial court erred in permitting the Commonwealth to pose the above-quoted voir dire

question because it did not further the proper purpose of voir dire, which, as this Court

has explained, is “to ensure the [empaneling] of a competent, fair, impartial, and

unprejudiced jury capable of following the instructions of the trial court.” Commonwealth

v. Knight, 241 A.3d 620, 640 (Pa. 2020) (citation omitted). Appellant further argued that

the voir dire question failed to correctly state the law because it did not instruct that (1)

the jury must believe the victim’s testimony beyond a reasonable doubt, and (2) the

testimony must be sufficient to establish each element of the crimes charged.

The Superior Court affirmed Appellant’s judgment of sentence in a unanimous

published opinion. With respect to the voir dire question, the court first observed that the

question derives from Pennsylvania Suggested Standard Criminal Jury Instruction

(“Pa.SSJI (Crim)”) § 4.13B,9 the note to which specifically indicates that the jury instruction

is consistent with the language of 18 Pa.C.S. § 3106; Section 3106, in turn, provides:

that the trial court allowed the voir dire question, and that Appellant did not waive his challenge thereto. 9 At the time of Appellant’s trial, Pa.SSJI (Crim) § 4.13B provided:

The testimony of [name of victim] standing alone, if believed by you, is sufficient proof upon which to find the defendant guilty in this case. The testimony of the victim in a case such as this need not be supported by other evidence to sustain a conviction. Thus you may find the defendant guilty if the testimony of [name of victim] convinces you beyond a reasonable doubt that the defendant is guilty. Pa.SSJI (Crim) § 4.13B (April 2005 - September 2024). In 2024, the language of § 4.13B was amended to read: (continued…)

[J-93-2024] - 3 The credibility of a complainant of an offense under this chapter shall be determined by the same standard as is the credibility of a complainant of any other crime. The testimony of a complainant need not be corroborated in prosecutions under this chapter. No instructions shall be given cautioning the jury to view the complainant’s testimony in any other way than that in which all complainants’ testimony is viewed. Walker, 305 A.3d at 17 (quoting 18 Pa.C.S. § 3106) (emphasis added).

The Superior Court determined that the Commonwealth had a proper purpose in

posing the voir dire question, which was to

identify jurors who hold fixed beliefs that are untenable under Section 3106 − specifically, the belief that a defendant’s guilt cannot be established beyond a reasonable doubt in a rape case (1) without DNA or other forensic evidence or (2) when the case boils down to the word of the complainant versus the word of the defendant (a so-called “he said, she said” case). Id.

The court further noted that, in two recent unpublished decisions, it held that “voir

dire questions identical in substance to the question herein were asked for a proper

purpose.” Id. at 17-18 (citing Commonwealth v. Antill, 2019 WL 2950181 (Pa. Super. filed

July 9, 2019) (finding no error by the trial court in permitting a voir dire question that

provided: “Under Pennsylvania law, the testimony of the victim standing alone, if believed

by you, is sufficient proof upon which to find the defendant guilty if the testimony of the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Witherspoon v. Illinois
391 U.S. 510 (Supreme Court, 1968)
Morgan v. Illinois
504 U.S. 719 (Supreme Court, 1992)
Commonwealth v. Ellison
902 A.2d 419 (Supreme Court of Pennsylvania, 2006)
Commonwealth v. Cox
686 A.2d 1279 (Supreme Court of Pennsylvania, 1996)
Commonwealth v. Moon
132 A.2d 224 (Supreme Court of Pennsylvania, 1957)
Commonwealth v. Montalvo
986 A.2d 84 (Supreme Court of Pennsylvania, 2009)
Commonwealth v. Kingsley
391 A.2d 1027 (Supreme Court of Pennsylvania, 1978)
Commonwealth v. Bomar
826 A.2d 831 (Supreme Court of Pennsylvania, 2003)
Commonwealth v. Paolello
665 A.2d 439 (Supreme Court of Pennsylvania, 1995)
Commonwealth v. Lopinson
234 A.2d 552 (Supreme Court of Pennsylvania, 1967)
Commonwealth v. Fisher
290 A.2d 262 (Supreme Court of Pennsylvania, 1972)
Commonwealth v. Richardson
473 A.2d 1361 (Supreme Court of Pennsylvania, 1984)
Commonwealth v. Johnson
305 A.2d 5 (Supreme Court of Pennsylvania, 1973)
Commonwealth v. Calhoun
86 A. 472 (Supreme Court of Pennsylvania, 1913)
Com. v. Walker, H.
2023 Pa. Super. 201 (Superior Court of Pennsylvania, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Commonwealth v. Walker, H., Aplt., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-walker-h-aplt-pa-2025.