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Keywords

defendantappealtrialfelonyprosecutorhearsayadmissibility

defendantappealtrialfelonyprosecutorappellanthearsaypiracy

Related Cases

Matthews v. United States, 13 A.3d 1181

Facts

On March 5, 2008, tattoo artist Jason Ingram hosted a tattoo party at an apartment where he was accompanied by his friend DuShawn Swann. After the party, as they were leaving, they were confronted by Matthews and his co-defendants, who attempted to rob them. Ingram witnessed Matthews wielding a baseball bat and saw Swann being shot during the altercation. Ingram later identified Matthews as one of the assailants, and evidence suggested that Matthews intended to rob Swann, who was assisting Ingram at the party.

Appellant Bryant Matthews was found guilty of conspiracy to commit robbery while armed, two counts of felony murder for the death of DuShawn Swann and two counts of attempted robbery while armed for the attempted robbery of Swann and his companion Jason Ingram. Matthews appeals these convictions alleging that the trial court erroneously admitted a hearsay statement of his co-defendant, that the prosecution was permitted to argue facts not in evidence in its closing, that there was insufficient evidence to convict him of the attempted armed robbery of Swann, and that the trial court improperly sentenced him because some of his convictions merge.

Issue

The main legal issues included whether the trial court erred in admitting a co-defendant's hearsay statement, whether the prosecution made improper comments during closing arguments, and whether there was sufficient evidence to support Matthews's conviction for attempted robbery.

1 codefendant's statement to witness that [victim] ran because he “got hit with a bat” did not implicate defendant's right of confrontation; 2 statement was admissible against codefendant as statement by party opponent; 3 prosecutor's comment during closing argument that victim had recognized defendant “by his face” was reasonable inference from evidence presented at trial; 4 prosecutor's comment in referring to position of victim's body as face-down when he was found, that victim could be “moving around, roll over, anything like that could have happened,” after he was shot was permissible inference from evidence presented; 5 evidence was sufficient to show that defendant had intended to rob victim; 6 defendant could not be convicted on two counts of felony murder based on alternative underlying theories arising from killing of single person; and 7 conviction for attempted robbery while armed merged with conviction for felony murder for which attempted robbery while armed served as underlying felony.

Rule

The court applied the rules regarding the admissibility of co-defendant statements under the Confrontation Clause and the standards for evaluating prosecutorial comments during closing arguments, as well as the sufficiency of evidence for criminal convictions.

The trial court found that Dubose's statement was not “in any way inculpatory with respect to Mr. Matthews,” and we agree. There was no reference to Matthews in Dubose's statement. He did not name Matthews or refer to him by any nickname. Dubose's passive statement that he witnessed “the tattoo man got hit with a bat” does not identify any assailant at all, much less Matthews.

Analysis

The court found that the co-defendant's statement did not implicate Matthews and was admissible against the co-defendant. The prosecution's comments during closing arguments were deemed reasonable inferences based on the evidence presented at trial. Additionally, the court concluded that there was sufficient evidence to support the jury's finding of Matthews's intent to rob Swann.

Conclusion

The court affirmed Matthews's convictions but remanded the case for resentencing due to the merger of certain felony murder and attempted robbery counts.

For the foregoing reasons, we find that (1) the trial court did not err in admitting Dubose's statement to Toyer because it did not implicate Matthews and the court gave a proper limiting instruction; (2) the trial court did not err in permitting the prosecution's closing remarks which were based on the evidence and rational inferences therefrom; (3) there was sufficient evidence that Matthews had the requisite intent to be convicted of the armed robbery while armed of Swann; and (4) one of Matthews's felony murder convictions must be vacated and the attempted robbery while armed conviction which underlies the remaining felony murder conviction must be vacated as the convictions merge.

Who won?

The prevailing party was the United States, as the court upheld Matthews's convictions on appeal.

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