beyond-a-reasonable-doubt standard in Pennsylvania

2018In support of the beyond-a-reasonable-doubt standard, the Story Court observed that it is "commensurate with the standard of proof in criminal trials that an accused cannot be convicted unless the trier of fact is convinced beyond a reasonable doubt that the accused is guilty as charged," noting "the danger that a lenient harmless error rule may denigrate the interests and policies which both constitutional and non-constitutional rules promote." Id. (citing In re Winship , 397 U.S. 358 , 90 S.Ct. 1068 , 25 L.Ed.2d 368 (1970) ).

2018In support of the beyond-a-reasonable-doubt standard, the Story Court observed that it is "commensurate with the standard of proof in criminal trials that an accused cannot be convicted unless the trier of fact is convinced beyond a reasonable doubt that the accused is guilty as charged," noting "the danger that a lenient harmless error rule may denigrate the interests and policies which both constitutional and non-constitutional rules promote." Id. (citing In re Winship , 397 U.S. 358 , 90 S.Ct. 1068 , 25 L.Ed.2d 368 (1970) ).

2023“The corpus delicti rule is two-tiered; it must first be considered as a rule of evidentiary admissibility using a prima facie standard, and later, under a beyond a reasonable doubt standard, as one of proof for the fact-finder's consideration at the close of the case.” Cuevas, 61 A.3d at 295 .

2015“The corpus delicti rule is two-tiered; it must first be considered as a rule of evidentiary admissibility using a prima facie standard, and later, under a beyond a reasonable doubt standard, as one of proof for the fact-finder’s consideration at the close of the case.” Id. citing Commonwealth v. Reyes, 381-82, 681 A.2d 724, 727 (Pa. 1996).

2020Story, 383 A.2d at 162 .

2018In support of the beyond-a-reasonable-doubt standard, the Story Court observed that it is "commensurate with the standard of proof in criminal trials that an accused cannot be convicted unless the trier of fact is convinced beyond a reasonable doubt that the accused is guilty as charged," noting "the danger that a lenient harmless error rule may denigrate the interests and policies which both constitutional and non-constitutional rules promote." Id. (citing In re Winship , 397 U.S. 358 , 90 S.Ct. 1068 , 25 L.Ed.2d 368 (1970) ).

2009County Court of Ulster County, N.Y. v. Allen, 442 U.S. 140, 157 , 99 S.Ct. 2213, 2225 , 60 L.Ed.2d 777 (1979); see also Commonwealth v. [Reginald] Hall, 574 Pa. 233 , 830 A.2d 537, 547-48 (2003).

2009County Court of Ulster County, N.Y. v. Allen, 442 U.S. 140, 157 , 99 S.Ct. 2213, 2225 , 60 L.Ed.2d 777 (1979); see also Commonwealth v. [Reginald] Hall, 574 Pa. 233 , 830 A.2d 537, 547-48 (2003).

2026Moreover, Barrett elucidated that its adoption of the beyond-a-reasonable-doubt standard was intended to prevent courts from conditioning the release of a contemnor from prison based on the “perform[ance of] acts beyond [the contemnor’s] power to perform,” thereby “convert[ing] a coercive sentence into a penal one without the safeguards of criminal procedure.” Barrett, 368 A.2d at 621 .

2026See Mendoza, 287 A.3d at 462 ; Rapak, 138 A.3d at 672 .

2022This is a faith which springs fundamentally from the requirement that unless guilt is established beyond all reasonable doubt, the accused shall go free.”25 Proof beyond a reasonable doubt represents society’s judgment concerning “the degree to which we weigh the injustice of letting a factually guilty person 22 Jones, 668 A.2d. at 1276. 23 Commonwealth v. Pursell, 724 A.2d 293, 314 (Pa. 1999) (citing Commonwealth v. Woodward, 394 A.2d 508 (Pa. 1978)). 24 See, e.g., Sullivan v. Louisiana, 508 U.S. 275, 281 (1993) (stating that the beyond a reasonable doubt standard is the “basic protection . .

2021Illegal Sentence - Muniz Appellant also claims his lifetime registration requirements (“LR requirements”) under Pennsylvania’s Sex Offender Registration and Notification Act are illegal under Commonwealth v. Muniz, 164 A.3d 1189 (Pa. 2017).7 He contends this is because his LR requirements under SORNA ____________________________________________ 7 As with Appellant’s previous issue, he couched this claim in terms of counsel’s ineffectiveness; however, we need only address the merit of the underlying illegal sentencing claim.

2021Id.

2020There, we held that the statutory mechanism for designating a defendant an SVP under SORNA I violated the United States Supreme Court’s decisions in Alleyne v. U.S., 570 U.S. 99 (2013),3 and Apprendi v. New Jersey, 530 U.S. 466 (2000).4 We reasoned that SORNA I required the trial court to make the SVP determination by “clear and convincing” evidence, rather than the beyond-a-reasonable- doubt standard and, thus, was unconstitutional.

2020There, we held that the statutory mechanism for designating a defendant an SVP under SORNA I violated the United States Supreme Court’s decisions in Alleyne v. U.S., 570 U.S. 99 (2013),3 and Apprendi v. New Jersey, 530 U.S. 466 (2000).4 We reasoned that SORNA I required the trial court to make the SVP determination by “clear and convincing” evidence, rather than the beyond-a-reasonable- doubt standard and, thus, was unconstitutional.

2020Moreover, this Court has explained, the beyond-a-reasonable-doubt standard reflects the prudent belief that “it is far worse to conclude incorrectly that the error was harmless than it is to conclude incorrectly that the error was reversible.” Davis, 305 A.2d at 719 .

2020Id.

2019Lord, supra. He has also waived his claim that his SVP status was imposed below the beyond-a-reasonable-doubt standard of proof.

2018However, in 1979, the United States Supreme Court, in Jackson v. Virginia, 443 U.S. 307 (1979), established that a criminal conviction must be supported by sufficient evidence, i.e., “evidence necessary to convince a trier of fact beyond a reasonable doubt of the existence of every element of the offense,” in order to ensure that it did not violate the Due Process Clause of the Fourteenth Amendment of the United States Constitution.