Commonwealth v. Ferguson

JOHNSON, Judge,

concurring:

I agree that the judgment of sentence should be affirmed and support the majority’s analysis on the sufficiency issue. I write separately, however, because I would find no arguable merit to Appellant’s ineffectiveness claim on the grounds that Appellant’s prior testimony in another case was admissible as a declaration against his penal interest. Commonwealth v. Colon, 461 Pa. 577, 337 A.2d 554 (1975); Commonwealth v. Ayala, 277 Pa.Super. 363, 419 A.2d 1187 (1980); Cf., F.R.Evid. 804(b)(1).

Not all declarations against penal interest are per se admissible. Such declarations must be made under circumstances that provide a considerable assurance of reliability recognizing the inherent unreliability of a confession exculpating possible accomplices at no cost to the declarant. Ayala, 277 Pa.Superior Ct. at 368, 419 A.2d at 1189.

In this case an assistant district attorney, who questioned Appellant in a separate criminal proceeding, made reference to the gas station robbery for which Appellant was charged in the instant case and Appellant admitted in the prior proceeding that he was the getaway driver.

This statement, in my view, was made by Appellant under circumstances which provided a considerable assurance of reliability since it directly implicated Appellant in the com*105mission of a crime. The ineffectiveness claim, therefore, has no arguable merit since the contested statement was admissible under the declaration against penal interest exception to the hearsay rule.