Commonwealth v. Lettau

Justice SAYLOR,

dissenting.

Like Mr. Justice Baer, I support the Superior Court’s position that the Commonwealth’s actions in this case were inappropriate and unduly prejudicial. As Justice Baer presently observes, the district attorney, as an initial matter, elicited testimony implicating Lettau’s pre-arrest silence or partial silence in a manner that did not comport with controlling precedent. See Dissenting Opinion, at 452-54, 986 A.2d at 124-26 (Baer, J.); accord Commonwealth v. Lettau, 955 A.2d 360, 363-67 (Pa.Super.2008) (providing a detailed overview of prevailing case law on the issue and distinguishing the present *451case from prior decisions permitting questioning relative to pre-arrest silence). The Superior Court explained, moreover, that

[w]hen Lettau later took the stand in his own defense, his counsel elicited his version of the interview with the trooper, ostensibly to counter the more critical version the jury had already heard from Trooper Fagley. In response, the Commonwealth ... repeatedly [questioned Lettau] on Trooper Fagley’s version of the telephone interview on every point.... In response to each inconsistency between Lettau’s testimony and the trooper’s account, the Commonwealth challenged the witness to characterize the trooper’s statement as a lie.
Compounding matters, the Commonwealth recalled Trooper Fagley after the defense rested its case and inquired, once again, about every nuance of his conversation with Lettau. Indeed, the portion of the transcription dedicated to the content of this single telephone conversation exceeds that allowed to develop the events that gave rise to the charges.

Id. at 366-67 (record citations omitted).

I find no fault with the Superior Court’s conclusion that, by persistently dwelling upon Lettau’s unwillingness to divulge certain information to the police during the pre-arrest time-frame, raising the issue in a manner inconsistent with prevailing fair-response doctrine, and then predicating its ultimate argument for guilt, in large degree, on Lettau’s pre-arrest silence in this regard, see N.T. Apr. 27, 2007, at 39 (“Why is [Lettau] preventing [the trooper] from doing a fair and full investigation[?] What’s that tell you about what [Lettau] knew, ladies and gentlemen[?]”); see also Dissenting Opinion, at 452-54, 986 A.2d at 123-24 (Baer, J.) (quoting other portions of the prosecutor’s closing argument), the Commonwealth impermissibly burdened Lettau’s Fifth-Amendment rights. Accord Lettau, 955 A.2d at 367 (“[T]he level of attention accorded the disparities in the witnesses’ testimony is so disproportionate to the testimony concerning the charged offenses, as to imply to lay jurors that the offense on trial is in fact the defendant’s failure to cooperate more fully with *452Trooper Fagiey.”). Under such circumstances, I agree with Justice Baer and the Superior Court majority that Lettau is entitled to a new trial.