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581 Pa. 45

863 A.2d 498

Commonwealth v. Crews

Supreme Court of Pennsylvania

Decided December 22, 2004

Supreme Court of Pennsylvania · decided 2004-12-22

Relies on Brady v. State of Maryland · Commonwealth v. Santiago · Commonwealth v. Marshall

Good law ✅— No negative treatment on recordhow we know

Decided 2004-12-22

How this case has been cited

Cited by 11 later decisions — most recently April 2013

11 state decisions

7020042010decided

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.

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¶1CONCURRING OPINION

Justice BAER.

¶2I join the majority opinion in all respects save one. Appellant argues that the Commonwealth failed to provide him with *56exculpatory material pursuant to Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963). The majority acknowledges Appellant’s contentions that “severe mental and emotional problems make him a very poor self-historian.” Op. at 502. Nevertheless, the majority opines that “it is not the Commonwealth’s responsibility to assess and atone for a defendant’s shortcomings as a client.” Id.

¶3While this may be so in cases where defendants do not suffer from mental infirmities and have access equal with the Commonwealth to alleged exculpatory material, the majority’s statement is too broad. Recently, in Commonwealth v. Santiago, 855 A.2d 682 (Pa.2004), a plurality of our Court noted that a defendant could not waive averments of incompetency in recognition that the very state of incompetency could impair one’s ability to recognize and raise the issue. See also, Commonwealth v. Marshall, 456 Pa. 313, 318 A.2d 724 (1974) (stating that it would be contradictory to argue that a defendant may be incompetent, and yet knowingly and intelligently waive his right to have the court determine his capacity to stand trial). An analogous Catch 22 could be applicable in cases where the Commonwealth is aware of exculpatory information which a defendant cannot understand or articulate because of mental illness. In such situations, it is, in my view, the Commonwealth’s responsibility “to assess a defendant’s shortcomings as a client” to the extent such shortcomings arise from emotional or mental health disorders, and to make disclosures regarding defendant’s history in recognition thereof. While in this case there is no indication of a Bradyviolation, under the circumstances referenced herein, there may, indeed, be.

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