closely related crimes exception in Pennsylvania

2026Id. ____________________________________________ 4 Post Conviction Relief Act, 42 Pa.C.S. § 9541-9546. - 15 - J-A29044-25 Our Supreme Court rejected that argument, however: Taylor conclusively established that there need not be common elements between the crimes charged for the closely related crimes exception to apply.

2024See Commonwealth v. Taylor, 831 A.2d 587, 596 (Pa. 2003) (“The closely related crimes exception does not require that the crimes share a common element.”). - 16 - J-S11030-24 had intent to transfer the firearms at the time he purchased them.” Brown’s Br. at 40.

2026“The historical purpose of the rule is to prevent a conviction based solely upon a confession or admission, where in fact no crime has been committed.” Id. - 13 - J-A29044-25 Here, the closely related crimes exception does not apply because the Commonwealth failed to establish the corpus of any crime arising from the same criminal episode as the offenses to which Appellant confessed.

2026See Taylor, 831 A.2d at 594-96 ; Fears, 836 A.2d at 67 .

2016Taylor, 831 A.2d at 594 (“[R]equiring the relationship between the crimes to be sufficiently close so as to avoid admitting a confession for a crime that did not occur, is the proper test for determining whether the closely related crimes exception to the corpus delicti rule applies.”); Bardo, 709 A.2d at 874 (“Here, appellant's confession related to two crimes and the Commonwealth's evidence established the corpus delicti of only one crime . . . . [T]he confession is admissible as to both crimes, for the relationship between the two crimes is close and the policy underlying the corpus delicti

2016Taylor, 831 A.2d at 594 (“[R]equiring the relationship between the crimes to be sufficiently close so as to avoid admitting a confession for a crime that did not occur, is the proper test for determining whether the closely related crimes exception to the corpus delicti rule applies.”); Bardo, 709 A.2d at 874 (“Here, appellant's confession related to two crimes and the Commonwealth's evidence established the corpus delicti of only one crime . . . . [T]he confession is admissible as to both crimes, for the relationship between the two crimes is close and the policy underlying the corpus delicti

2020In addition, “under the closely related crimes exception to the corpus delicti rule, where a defendant’s confession relates to separate crimes with which he is charged, and where independent evidence establishes the corpus delicti of only one of those crimes, the confession may be admissible as evidence of the commission of the other crimes as well.” Commonwealth v. Hernandez, 39 A.3d 406, 413 (Pa. Super. 2012).

2015Pursuant to the closely related crimes exception, “where a defendant’s confession relates to separate crimes with which he is charged, and where independent evidence establishes the corpus delicti of only one of those crimes, the confession may be admissible as evidence of the commission of the other crimes.” Commonwealth v. Dupre, 866 A.2d 1089, 1099 (Pa. Super. 2005), appeal denied, 879 A.2d 1089 (Pa. 2005) (citation omitted).

2012See Otterson, supra, Taylor, supra; see also Young, supra at 957 n. 9 (Pa.Super.2006) (statement made after receiving Miranda warnings by appellant to police officer to explain his actions admissible despite challenge to corpus delicti rule), (citing Commonwealth v. Ogrod, 576 Pa. 412 , 889 A.2d 294, 320 (2003), cert. denied, 543 U.S. 1188 , 125 S.Ct. 1395 , 161 L.Ed.2d 192 (2005)).

2012See Otterson, supra, Taylor, supra; see also Young, supra at 957 n. 9 (Pa.Super.2006) (statement made after receiving Miranda warnings by appellant to police officer to explain his actions admissible despite challenge to corpus delicti rule), (citing Commonwealth v. Ogrod, 576 Pa. 412 , 889 A.2d 294, 320 (2003), cert. denied, 543 U.S. 1188 , 125 S.Ct. 1395 , 161 L.Ed.2d 192 (2005)).

2012See Otterson, supra, Taylor, supra; see also Young, supra at 957 n. 9 (Pa.Super.2006) (statement made after receiving Miranda warnings by appellant to police officer to explain his actions admissible despite challenge to corpus delicti rule), (citing Commonwealth v. Ogrod, 576 Pa. 412 , 889 A.2d 294, 320 (2003), cert. denied, 543 U.S. 1188 , 125 S.Ct. 1395 , 161 L.Ed.2d 192 (2005)).

2012See Otterson, supra, Taylor, supra; see also Young, supra at 957 n. 9 (Pa.Super.2006) (statement made after receiving Miranda warnings by appellant to police officer to explain his actions admissible despite challenge to corpus delicti rule), (citing Commonwealth v. Ogrod, 576 Pa. 412 , 889 A.2d 294, 320 (2003), cert. denied, 543 U.S. 1188 , 125 S.Ct. 1395 , 161 L.Ed.2d 192 (2005)).

2012See Otterson, supra; see also Commonwealth v. Taylor, 574 Pa. 390 , 831 A.2d 587, 595-96 (2003) (holding closely related crimes exception does not require that crimes share common element). 10 In this case, Appellant was charged with three closely related crimes: sale or transfer of a firearm, criminal conspiracy (illegal transfer of a firearm), and lending or giving of firearms prohibited.

2012See Otterson, supra, Taylor, supra; see also Young, supra at 957 n. 9 (Pa.Super.2006) (statement made after receiving Miranda warnings by appellant to police officer to explain his actions admissible despite challenge to corpus delicti rule), (citing Commonwealth v. Ogrod, 576 Pa. 412 , 889 A.2d 294, 320 (2003), cert. denied, 543 U.S. 1188 , 125 S.Ct. 1395 , 161 L.Ed.2d 192 (2005)).

2012See Otterson, supra, Taylor, supra; see also Young, supra at 957 n. 9 (Pa.Super.2006) (statement made after receiving Miranda warnings by appellant to police officer to explain his actions admissible despite challenge to corpus delicti rule), (citing Commonwealth v. Ogrod, 576 Pa. 412 , 889 A.2d 294, 320 (2003), cert. denied, 543 U.S. 1188 , 125 S.Ct. 1395 , 161 L.Ed.2d 192 (2005)).

2012See Otterson, supra, Taylor, supra; see also Young, supra at 957 n. 9 (Pa.Super.2006) (statement made after receiving Miranda warnings by appellant to police officer to explain his actions admissible despite challenge to corpus delicti rule), (citing Commonwealth v. Ogrod, 576 Pa. 412 , 889 A.2d 294, 320 (2003), cert. denied, 543 U.S. 1188 , 125 S.Ct. 1395 , 161 L.Ed.2d 192 (2005)).

2003See Pierce, 786 A.2d at 221 (“[ajbsent a demonstration of prejudice, [a PCRA petitioner] cannot prevail on a claim for ineffective assistance of counsel and no further inquiry is warranted”).