Commonwealth of Pennsylvania, Appellee v. Dustin Ford Briggs, Appellant

Summary

The Supreme Court of Pennsylvania affirmed Dustin Briggs's convictions for two counts of first-degree murder and one count of robbery and the resulting sentence of death, finding the trial evidence legally sufficient and rejecting his challenges to the denial of four change-of-venue motions, the admission of his spontaneous jailhouse apology, the denial of defense evidence-testing, the Attorney General's assumption of the prosecution, several jury-selection rulings, and limits on cross-examination and prior-bad-acts testimony. Although portions of the pretrial publicity were presumptively prejudicial, the court concluded a sufficient cooling-off period elapsed, coverage diminished, and only 12 percent of examined jurors held fixed unalterable opinions (all excused for cause), and that Trooper Pelachick neither interrogated Briggs in violation of the Fifth Amendment nor deliberately elicited his statement in violation of the Sixth. Justice Saylor dissented, contending the trooper deliberately elicited the incriminating statement after Briggs invoked counsel and would have remanded for a harmless-error determination.