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570 Pa. 263

809 A.2d 256

Commonwealth v. Demarco

Supreme Court of Pennsylvania

Decided October 23, 2002

Supreme Court of Pennsylvania · decided 2002-10-23

Good law ✅— No negative treatment on recordhow we know

Decided 2002-10-23

How this case has been cited

Cited by 29 later decisions — most recently December 2018 · most notably Commonwealth v. Markman (2007), Commonwealth v. Hairston (2014)

2 federal appellate · 25 state decisions

16020022010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

Justice EAKIN,

¶1Concurring.

¶2I agree with the proposition that the statute trumps the “three pronged test,” and that the defense was entitled to the instruction, despite contrary language in the caselaw. While defendant never testified, the evidence included his prior testimony of threats, making the duress instruction appropriate, and I therefore concur in the reversal of the prior decision. However, I cannot agree with the broad statements of what is and is not relevant and admissible evidence as concerns this defense.

¶3The test involves (1) a person of reasonable firmness, (2) in the accused’s circumstance. I believe the language used by my colleagues elevates the accused’s subjective mental firmness into the equation; this is not part of the statute, comments from the 1960 tentative draft of the Model Penal Code *277notwithstanding. These broad strokes open the way for “experts” to offer hindsight opinions about what a defendant could and could not resist, which is the ultimate issue for the jury. Considerations of retardation and such may be relevant in a given case, but they are not determinative of this appeal; I would let them for another day when they are squarely presented.

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