In re Cnty. Investigating Grand Jury XXV, 67 A.3d 716 (Pa. 2013). · Go Syfert
In re Cnty. Investigating Grand Jury XXV, 67 A.3d 716 (Pa. 2013). Cases Citing This Book View Copy Cite
“when the trial court gives adequate cautionary instructions, declaration of a mistrial is not necessary.”
245 citation events (245 in the last 25 years) across 7 distinct courts.
Strongest positive: Commonwealth v. Laird (pa, 2015-07-20)
Treatment trajectory · 2013 → 2026 · click a year to view as-of
2013 2019 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Commonwealth v. Laird
Pa. · 2015 · signal: see · quote attribution · 1 verbatim quote · confidence high
when the trial court gives adequate cautionary instructions, declaration of a mistrial is not necessary.
cited Cited as authority (rule) Com. v. Christian, T.
Pa. Super. Ct. · 2026 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
cited Cited as authority (rule) Com. v. Santibanez, S.
Pa. Super. Ct. · 2026 · confidence medium
“The admissibility of evidence [at sentencing] rests with the sound discretion of the trial court.” Commonwealth v. Bryant, 67 A.3d 716, 726 (Pa. 2013).
examined Cited as authority (rule) Com. v. Adams Diaz, S. (5×) also: Cited "see", Cited "see, e.g."
Pa. Super. Ct. · 2026 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
discussed Cited as authority (rule) Com. v. Hawkins, Q.
Pa. Super. Ct. · 2025 · confidence medium
Commonwealth v. Bryant, 620 Pa. 218 , 67 A.34 716, 727 (2013); Commonwealth v. Hutchinson, Commonwealth v. Bryant, 620 Pa. 218 , 67 A.3d 716, 727 (2013); Commonwealth v. Hutchinson, 611 Pa. 280 , 25 A.3d 277, 307 (2011).
discussed Cited as authority (rule) Com. v. Anderson, B.
Pa. Super. Ct. · 2025 · confidence medium
Christine, Christine, 633 633 Pa. Pa. 389, 389, 397, 397, 125 125 A.3d A.3d394, 394,398 398 (2015) (2015) quoting quotingCommonwealth Commonwealt v. Bryant, v. Bryant, 620 Pa. 218, 235 , 67 A.3d 716 , 726 (2013) quoting Commonwealth v. Eichenger, 591 620 Pa. 218, 235 , 67 A.3d 716, 726 (2013) quoting Commonwealth ».
cited Cited as authority (rule) Com. v. Procopio, S.
Pa. Super. Ct. · 2025 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
discussed Cited as authority (rule) Com. v. Valona, G.
Pa. Super. Ct. · 2025 · confidence medium
“It is not sufficient to persuade the appellate court that it might have reached a different conclusion[, rather,] it is necessary to show an actual abuse of the [trial court’s] discretionary power.” Commonwealth v. Bryant, 67 A.3d 716, 726 (Pa. 2013) (citation and quotation marks omitted).
cited Cited as authority (rule) Com. v. Fields, R.
Pa. Super. Ct. · 2025 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
cited Cited as authority (rule) In the Int. of: I.M., Appeal of: I.M.
Pa. Super. Ct. · 2025 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
discussed Cited as authority (rule) Com. v. Wood, A.
Pa. Super. Ct. · 2024 · confidence medium
“It is not sufficient to persuade the appellate court that it might have reached a different conclusion[, rather,] it is necessary to show an actual abuse of the [trial court’s] discretionary power.” Commonwealth v. Bryant, 67 A.3d 716, 726 (Pa. 2013) (citation and quotation marks omitted).
discussed Cited as authority (rule) Com. v. Coffee, T.
Pa. Super. Ct. · 2024 · confidence medium
"It is well-established that 'comments by a prosecutor constitute reversible error only where their unavoidable effect is to prejudice the jury, forming in [the jurors'] minds a fixed bias and hostility toward the defendant such that they could not weigh the evidence objectively and 25 render a fair verdict."' Commonwealth v. Arrington, 86 A.3d 831, 853 (Pa. 2014) (quoting Commonwealth v. Bryant, 67 A.3d 716, 727 (Pa. 2013).
cited Cited as authority (rule) Com. v. Fornwald, T.
Pa. Super. Ct. · 2024 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
cited Cited as authority (rule) Com. v. Ghimirey, J.
Pa. Super. Ct. · 2024 · confidence medium
Commonwealth v. Bryant, 620 Pa. 218, 232 , 67 A.3d 716, 724 (2013) (quoting Commonwealth v. Perez, 577 Pa. 360, 374-75 , 845 A.2d 779, 788 (2004)).
discussed Cited as authority (rule) Com. v. Shields, T.
Pa. Super. Ct. · 2024 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013) (citations omitted); Commonwealth v. Riggle, 119 A.3d 1058, 1068 (Pa. Super. 2015). - 18 - J-A28045-23 The final portion of the Commonwealth’s summation was, in context, an aggressive argument by the prosecutor to rebut the attacks on the victim, an admitted drug dealer, while providing the jury with a reason for why they had spent a week in trial over an alleged drug debt that turned violent.
cited Cited as authority (rule) Com. v. Shields, C.
Pa. Super. Ct. · 2024 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013) (citations omitted); Commonwealth v. Riggle, 119 A.3d 1058, 1068 (Pa. Super. 2015).
discussed Cited as authority (rule) Com. v. Qawiee, A.
Pa. Super. Ct. · 2024 · confidence medium
This issue concerns the admissibility of evidence, which rests within the sound discretion of the trial court, and therefore, we “will reverse [the] trial court’s decision … only if the appellant sustains the ‘heavy burden’ to show - 10 - J-A10034-24 that the trial court has abused its discretion.” Commonwealth v. Bryant, 67 A.3d 716, 726 (Pa. 2013) (citations omitted).
discussed Cited as authority (rule) Com. v. Blackston, M.
Pa. Super. Ct. · 2024 · confidence medium
It is well established that “[a] trial court may grant a mistrial only where the incident upon which the motion is based is of such a nature that its unavoidable effect is to deprive the defendant of a fair trial by preventing the jury from weighing and rendering a true verdict.” Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013) (citation omitted).
discussed Cited as authority (rule) Com. v. Brooks, T. (2×) also: Cited "see"
Pa. Super. Ct. · 2023 · confidence medium
A mistrial is an extreme remedy that is appropriate “only where the incident upon which the motion is based is of such a nature that its unavoidable effect is to deprive the defendant of a fair trial by preventing the jury from weighing [the evidence] and rendering a true verdict.” Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
cited Cited as authority (rule) Com. v. Williams, K.
Pa. Super. Ct. · 2023 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 724 (Pa. 2013) (citation omitted).
discussed Cited as authority (rule) Com. v. Murphy, J.
Pa. Super. Ct. · 2023 · confidence medium
We will reverse and remand for a new trial only when the “unavoidable effect [of the statements] is to prejudice the jury, forming in the jurors’ minds a fixed bias and hostility toward the defendant such that they could not weigh the evidence objectively and render a fair verdict.” Id. at 853 (quoting Commonwealth v. Bryant, 67 A.3d 716, 727 (Pa. 2013) (brackets omitted)). - 13 - J-S20027-23 A prosecutor has “reasonable latitude” in an opening statement, which should “apprise the jury of how the case will develop, its background[,] and what will be attempted to be proved.” Commo…
cited Cited as authority (rule) Com. v. Rosa, E.
Pa. Super. Ct. · 2023 · confidence medium
“In reviewing a trial court’s denial of a motion for a mistrial, our standard is abuse of discretion.” Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
cited Cited as authority (rule) Com. v. Dickerson, D.
Pa. Super. Ct. · 2023 · confidence medium
Commonwealth v. Leap, 222 A.3d 386, 392 (Pa. Super. 2019) (citing Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013)).
discussed Cited as authority (rule) Com. v. Bailey, D.
Pa. Super. Ct. · 2023 · confidence medium
With regard to victim impact statements, this Court recently explained: “The admissibility of evidence, including victim impact evidence, rests with the sound discretion of the trial court.” -7- J-A02024-23 Commonwealth v. Bryant, 67 A.3d 716, 726 (Pa. 2013).
cited Cited as authority (rule) Com. v. Rosario, J.
Pa. Super. Ct. · 2022 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 727-28 (Pa. 2013) (citations and internal quotation marks omitted) (brackets in original).
discussed Cited as authority (rule) Com. v. Knight, A. (2×)
Pa. Super. Ct. · 2022 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013). “[N]ot every inappropriate remark by a prosecutor constitutes reversible error.” Commonwealth v. Noel, 53 A.3d 848, 858 (Pa. Super. 2012).
cited Cited as authority (rule) Com. v. Dejesus-Gonzalez, J.
Pa. Super. Ct. · 2022 · confidence medium
However, if the trial court gives adequate cautionary instructions, “declaration of a mistrial is not necessary.” Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
discussed Cited as authority (rule) Com. v. Otero-Velez, D.
Pa. Super. Ct. · 2022 · confidence medium
Likewise, "circumstantial evidence[, by which the Commonwealth may prove specific intent,] may consist of the accused’s use of a deadly weapon on a vital part of the victim’s body.” Commonwealth v. Cox, 728 A.2d 923, 929 (Pa. 1999); Commonwealth v. Bryant, 67 A.3d 716, 721 (Pa. 2013).
cited Cited as authority (rule) Com. v. Sones, T.
Pa. Super. Ct. · 2022 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
discussed Cited as authority (rule) Com. v. Ivy, G.
Pa. Super. Ct. · 2022 · confidence medium
Nevertheless, even if a prosecutor’s remarks were prejudicial, “prejudice by prosecutorial remarks can be cured by instructions from the trial court.” Commonwealth v. Carter, 643 A.2d 61, 77 (Pa. 1994); see also Jones, 668 A.2d at 504 (law presumes jury will follow trial court’s curative instructions); Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013) (new trial not warranted where trial court gives adequate cautionary instruction).
discussed Cited as authority (rule) Com. v. McKenzie, E. (2×) also: Cited "see"
Pa. Super. Ct. · 2022 · confidence medium
In his second issue, McKenzie argues that “the court erred in denying [his] motion[] for a mistrial” where “the District Attorney committed prosecutorial misconduct by insinuating that [McKenzie] had a prior criminal record in front of the jury.” (McKenzie’s Brief, at 13, 15).5, 6 The Commonwealth maintains that this issue is waived and would not merit relief because this issue was decided previously by this Court in Commonwealth v. Lunsford, 2021 WL 2531151 , unpublished memorandum, (Pa. Super. filed ____________________________________________ 5 It is well-settled that the award of…
discussed Cited as authority (rule) Com. v. Fiorentino, A.
Pa. Super. Ct. · 2022 · confidence medium
Nevertheless, even if a prosecutor’s remarks were prejudicial, “prejudice by prosecutorial remarks can be cured by instructions from the trial court.” Commonwealth v. Carter, 643 A.2d 61, 77 (Pa. 1994); see also Commonwealth v. Jones, 668 A.2d 491 , 504 (Pa. 1994) (law presumes jury will follow trial court’s curative instruction); Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013) (new trial not warranted where trial court gives adequate cautionary instruction).
discussed Cited as authority (rule) Com. v. Seals, D.
Pa. Super. Ct. · 2022 · confidence medium
When on review, “[c]omments by a prosecutor constitute reversible error only where their unavoidable effect is to prejudice the jury, forming in the jurors' minds a fixed bias and hostility toward the defendant such that they could not weigh the evidence objectively and render a fair verdict.” Commonwealth v. Bryant, 67 A.3d 716, 727 (Pa, 2013) (internal markings and citations omitted).
discussed Cited as authority (rule) Com. v. Richardson, A. (2×) also: Cited "see"
Pa. Super. Ct. · 2021 · confidence medium
Furthermore, “[w]hen the trial court gives adequate cautionary instructions, - 18 - J-S22027-21 declaration of a mistrial is not necessary.” Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
cited Cited as authority (rule) Com. v. Johnson, J.
Pa. Super. Ct. · 2021 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
discussed Cited as authority (rule) Com. v. Lunsford, W. (2×) also: Cited "see"
Pa. Super. Ct. · 2021 · confidence medium
Jury Trial, 12/12/19, at 50. -5- J-A06028-21 such a nature that its unavoidable effect is to deprive the defendant of a fair trial by preventing the jury from weighing and rendering a true verdict.” See Commonwealth v. Bryant, 67 A.3d 716, 727-28 (Pa. 2013) (quoting Commonwealth v. Chamberlain, 30 A.3d 381, 408 (Pa. 2011) and Commonwealth v. Travaglia, 28 A.3d 868, 879 (Pa. 2011)).
discussed Cited as authority (rule) Com. v. Veasy, J. (2×) also: Cited "see"
Pa. Super. Ct. · 2020 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 724 (Pa. 2013) (citation omitted).
cited Cited as authority (rule) State of Iowa v. Jacob A. Boothby
Iowa · 2020 · confidence medium
Ct. App. 2010); Francis v. State, 781 N.W.2d 892, 895 (Minn. 2010); Commonwealth v. Bryant, 67 A.3d 716, 722 (Pa. 2013).
cited Cited as authority (rule) State of Iowa v. Jacob A. Boothby
Iowa · 2020 · confidence medium
Ct. App. 2010); Francis v. State, 781 N.W.2d 892, 895 (Minn. 2010); Commonwealth v. Bryant, 67 A.3d 716, 722 (Pa. 2013).
discussed Cited as authority (rule) Com. v. Veasy, J. (2×) also: Cited "see"
Pa. Super. Ct. · 2020 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 724 (Pa. 2013) (citation omitted).
discussed Cited as authority (rule) Com. v. Brozenick, R. (2×) also: Cited "see"
Pa. Super. Ct. · 2020 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
discussed Cited as authority (rule) Com. v. Adams, J.
Pa. Super. Ct. · 2020 · confidence medium
Our Supreme Court has recognized that “[w]hen the trial court gives adequate cautionary instructions, declaration of a mistrial is not necessary.” Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013) (citation omitted).
examined Cited as authority (rule) Com. v. Moore, M. (3×) also: Cited "see"
Pa. Super. Ct. · 2020 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 724 (Pa. 2013) (citation omitted).
examined Cited as authority (rule) BRYANT v. GILMORE (3×)
E.D. Pa. · 2020 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 720 (2013).
discussed Cited as authority (rule) Com. v. Minnich, C. (2×) also: Cited "see"
Pa. Super. Ct. · 2020 · confidence medium
When the evidence supports the factual findings, we are bound by such findings; we may reverse only if the legal conclusions drawn therefrom are erroneous. -8- J-A01015-20 Commonwealth v. Bryant, 67 A.3d 716, 724 (Pa. 2013) (citation omitted).
discussed Cited as authority (rule) Com. v. Myers, J.
Pa. Super. Ct. · 2020 · confidence medium
A. Relevant Legal Principles The admissibility of evidence rests within the sound discretion of the trial court and its decision will only be reversed if the court's conclusion "overrides or misapplies the law, or where the judgment exercised is manifestly unreasonable, or the result of partiality, prejudice, bias or ill-will." Commonwealth v. Bryant, 67 A.3d 716, 726 (Pa. 2013).
discussed Cited as authority (rule) Com. v. Lee, A.
Pa. Super. Ct. · 2020 · confidence medium
“A trial court should grant a motion for mistrial only where the incident upon which the motion is based is of such a nature that its unavoidable effect -8- J-S59041-19 is to deprive the defendant of a fair trial by preventing the jury from weighing and rendering a true verdict.” Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013) (citing Chamberlain, 30 A.3d at 422 ).
cited Cited as authority (rule) Com. v. Valdez-Torres, R.
Pa. Super. Ct. · 2019 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 721 (Pa. 2013).
cited Cited as authority (rule) Com. v. Leap, J.
Pa. Super. Ct. · 2019 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
cited Cited as authority (rule) Com. v. Leap, J.
Pa. Super. Ct. · 2019 · confidence medium
Commonwealth v. Bryant, 67 A.3d 716, 728 (Pa. 2013).
Retrieving the full opinion text from the archive…
In re COUNTY INVESTIGATING GRAND JURY XXV FOR THE CITY OF PHILADELPHIA. Petition of R.L., Witness
No. 30 EM 2013.
Supreme Court of Pennsylvania.
May 23, 2013.
67 A.3d 716
Cited by 1 opinion  |  Published

ORDER

PER CURIAM.

AND NOW, this 23rd day of May, 2013, the Motion to File Under Seal is GRANTED, and the Petition for Review, the Petition for Leave to File Reply, and the Motion Seeking Leave to File Supplement to Petition for Leave to File Reply to the Commonwealth’s Answer are DENIED.