Com v. Yandamuri: Direct Capital Appeal

Com v. Yandamuri was a direct capital appeal case pursuant to the Court’s responsibility to directly review all death penalty cases. In a botched baby-kidnapping-for-ransom attempt, Raghunandan Yandamuri, a non-citizen, knocked on the door of the home of friends, forced entry and threatened the grandmother with a four-inch knife. The grandmother struggled when Yandamuri grabbed the baby, and he stabbed Grandmother in the throat several times, killing her. He then stuffed a cloth in the baby’s mouth, bound the baby’s head with a towel (to keep the cloth in place), and then stuffed the child in a suitcase and left the suitcase in a sauna while he showered.

Yandamuri’s “plan,” such as it was, unraveled when he used an identifiable term for the parents known to only a small group of friends on the ransom notes strewn about the scene of the crime. He was in a casino when approached by security and asked if he would meet police in a hallway. He complied, and voluntarily accompanied the police to the station, and from there, the story is simple. He was repeatedly told he could leave at any time, and as his story changed, he finally was read Miranda rights, and he gave a full confession.

Yandamuri’s challenge to his conviction for first-degree murder is as weak as his plan for ransom. He challenged his “detention,” the admissibility of his confessions and claimed that “discrepancies” in the stories of the Commonwealth’s witnesses constituted “false evidence.” These arguments were flatly rejected.

Baer for the Majority: No Custodial Interrogation, Miranda not Required

Justice Baer, speaking for the majority upheld the conviction. Yandamuri’s first argument is that he was illegally arrested and detained. But the facts clearly demonstrated that he was first approached by private security guards at the casino where he was gaming, and he agreed to go with the guards, then with the police, and that he voluntarily remained with the police at the station in an unlocked room, even after repeatedly being reminded he was free to leave.

Second, Yandamuri argued that his confessions were coerced because he was not Mirandized early enough in the process. In determining whether a Defendant was in custodial interrogation such that Miranda warnings are required, the courts use an objective test, asking whether a reasonable person would have believed he was at liberty to terminate the police encounter under the circumstances. In this case, the officers’ repeated reminders that he was free to leave, their offer that he take breaks for food or to use the restroom, and the fact that Mr. Yandamuri had a master’s degree, implying high intelligence that makes it unlikely he was psychologically coerced.

The Court notes only two factors in his favor: Yandamuri is not a citizen, and thus “may have been unfamiliar with police practices” here in America; and he was at the police station for thirteen hours before confessing—his final confession came early in the hours of the morning. But nothing else in the situation argued in favor of a coerced confession, and so the confession could be properly admitted.

Finally, the Court rejected Defendant’s argument that minor discrepancies in the testimony of witnesses for the Commonwealth constituted the presentation of “false evidence.” Discrepancies, by themselves, are not false evidence.

Conclusion: You Can Always Waive Your Rights

These cases are always heartbreaking—especially when they deal with a murdered baby, and a grandmother who tried, however futilely, to wrest the baby back from the kidnapper. This case provides little of interest to the practicing attorney, but reaffirms the basic principle that constitutional protections cannot be foisted on those who are not interested in preserving them. The evidence used to convict Yandamuri came largely from his own mouth.

Com v. Smyrnes: Capital Appeal

The facts in this case are a repeat of those in Com v. Knight, and they are horrific enough not to bear repeating. Smyrnes appears to have been the ringleader of the conspirators described in the previous appeal. As a matter of both practice and public interest, this case hardly warrants a review, as the Supreme Court of Pennsylvania reviewed and affirmed all matters of the trial. Indeed, most of the points of review were deemed to have been waived by the Defendant, whose failure to object, and indeed, his endorsement of the trial court’s rulings led the Court to refuse further discussion of most of his objections.

Two points stand out, however: first, the Court takes a moment to caution prosecutors on “the value of restraint in scenarios involving potential prejudice connected with . . . non-essential evidence” such as photographs of victims. Here, the Commonwealth made limited use of a pre-injury photograph of the mentally disabled victim to demonstrate what she looked like before her hair was cut by the defendant.

This portion of the opinion represents a possible refinement on prior caselaw, which held that photographs of a victim may not be entered to prove an uncontested element of a crime, or to demonstrate a “victim’s character or physical abilit[y].” Com v. Rivers, 537 Pa. 394, 406-07 (1994). This is in keeping with Pennsylvania Rule of Evidence 403, which requires a balancing of the unfair prejudice created by a piece of evidence with its probative value.

It is plain that the Court did not approve of the use of the photograph in this case, as it “was by no means essential to the prosecution to place this photograph before the jury.” The Court goes on to argue that it “had some relevance,” and to rest its decision on the Commonwealth’s “limited use” of the photo. Of course, “relevance” is only a baseline of admissibility under Pa.R.E. 402, and Rule 403’s balancing test is left unaddressed by the Court. It is hard to see how a photograph was necessary to prove that the victim’s hair was cut during the torture sequence preceding her murder, and a photograph proving that she once had long hair could hardly be argued to be probative. The Court more properly should have ruled this an error, but ruled it harmless and unprejudicial to the defense; however, the Court appears to be squeamish about admitting even a minor fault in a death penalty case that it has no intention of remanding for a new trial.

Second, the Defendant raised a novel argument that the aggravating factor of a murder “committed by means of torture” in 42 Pa.C.S. § 9711(d)(8) could not be imputed to a conspirator who was not the “instrumentality of death.” The Defendant was found vicariously responsible for murder by virtue of his encouragement of the others, his leadership in the conspiracy to murder, and his malicious state of mind. But while the Defendant participated in the acts of torture, he did not give the final blows of the knife that killed the victim, and argued he could not properly be attributed with the aggravating circumstance of torture for the purpose of reaching a death penalty verdict. The Court notes that, although the active voice is required elsewhere in the aggravating factors statute, the passive voice referring to an offense “committed by means of torture” clearly demonstrates the propriety of the torture aggravator even when the Defendant was not the physical murderer.

Capital Appeals are statutorily-required of the Commonwealth’s High Court, to ensure that a sentence is not “the product of passion, prejudice, or any other arbitrary factor,” and to ensure that the aggravating factors were properly found by the jury. 42. Pa.C.S. § 9711(h)(3). The resulting opinions rarely make for interesting reading or for novel caselaw, but they serve an important role in ensuring the justice of executions.