Commonwealth v. Hathaway
500 A.2d 443, 347 Pa. Super. 134, 1985 Pa. Super. LEXIS 9901 (1985)
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Rule of Law:
A trial court has broad discretion over the scope of voir dire, and its refusal to permit specific questions will not be reversed unless a palpable error is established.
Facts:
- Byron Hathaway and his wife, Bernadette Hathaway, were estranged.
- On April 28, 1981, Byron Hathaway met his wife at their son's school after she had dropped the boy off.
- After a brief conversation, Hathaway pulled out a .32 caliber pistol.
- Bernadette Hathaway attempted to run away, but Hathaway pursued her and fired several shots, causing her to fall.
- Hathaway then walked over to her body, reloaded the pistol, placed it at her head, and fired several more shots.
- He returned to his car and drove away before being apprehended by police several blocks from the scene.
Procedural Posture:
- Byron Hathaway was tried before a jury in a Pennsylvania court of first instance for first-degree murder and possession of firearms without a license.
- At trial, Hathaway did not dispute that he killed his wife but presented a diminished capacity defense.
- The jury found Hathaway guilty of first-degree murder and the firearms charge on December 11, 1981.
- Hathaway filed post-verdict motions for a New Trial and in Arrest of Judgment, which the trial court overruled.
- Hathaway (appellant) appealed the judgment of sentence to the Superior Court of Pennsylvania.
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Issue:
Does a trial court abuse its discretion by refusing to permit a defendant to ask prospective jurors specific questions about their potential biases concerning psychiatric defenses, handgun ownership, prior jury service, or familial experience with domestic violence, when the court asks more general questions on these topics?
Opinions:
Majority - Beck, J.
No. A trial court does not abuse its discretion by limiting specific voir dire questions when the court's own general inquiries are sufficient to ensure a competent, fair, and impartial jury. The purpose of voir dire is to uncover fixed opinions that would prevent a juror from being impartial, not to provide a defendant with a basis for exercising peremptory challenges. Here, the trial court's general questions about biases against psychiatric testimony and being a victim of violence were sufficient. Questions about handgun ownership were not relevant to a disputed issue, as Hathaway admitted to the shooting, and questions about prior jury service have no reasonable correlation to a juror's ability to be fair. The court's refusal to permit questions about the 'irresistible impulse' defense was also proper, as this defense is not recognized in Pennsylvania and is distinct from the diminished capacity defense that Hathaway was asserting.
Analysis:
This decision reinforces the significant discretion afforded to trial judges in managing the voir dire process in non-capital cases. It establishes that a defendant's right to an impartial jury does not extend to an unlimited right to probe every potential source of bias with highly specific questions, especially when the trial judge's more general questions are sufficient to uncover disqualifying prejudice. The ruling sets a high bar for reversal on appeal, requiring a showing of 'palpable error' rather than mere disagreement with the judge's choices. This precedent gives trial courts substantial control over the efficiency and focus of jury selection, limiting inquiries to those essential for seating a fair panel.
