Pennsylvania v. Hoover (majority)
Annotate this CaseIn 2012, the Commonwealth filed a criminal complaint against appellee Jason Hoover alleging he and two co-conspirators, Barry Martell and D.M. (a juvenile), stole parts and equipment from RES Coal Company and later sold the stolen parts to a local salvage yard. The Commonwealth appealed Superior Court Order vacating appellee’s judgment of sentence for theft by unlawful taking, receiving stolen property, criminal conspiracy, and corruption of minors, and remanding for a new trial. The Superior Court concluded that the trial court abused its discretion in determining that the probative value of appellee’s prior crime of dishonesty substantially outweighed its prejudicial effect. The Supreme Court reversed and remanded: "[t]here was no need, or warrant, for the Superior Court to seek to innovate a novel standard for admitting a prior conviction for impeachment purposes, particularly one based on federal sources, since the applicable Pennsylvania Rule of Evidence and the corresponding federal rule, F.R.E. Rule 609, are quite distinct. Thus, while subsection (d)(2) of the corresponding federal rule limits the admissibility of juvenile adjudications to those of witnesses other than the defendant, subsection (d) of the Pennsylvania rule, as stated, contains no such limitation, but specifically allows the use of juvenile adjudications for impeachment purposes. Thus under Pennsylvania law, prior adult convictions of crimes of dishonesty remain fair game for impeachment in appropriate circumstances. The case was remanded for the Superior Court to consider appellee’s remaining claim regarding appellee’s proposed alibi testimony.
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