Pennsylvania v. Molina (opinion announcing the judgment of the court)
Annotate this CaseA jury convicted defendant Michael Molina of third degree murder and related crimes resulting from the savage beating of Melissa Snodgrass, apparently as a result of drug debts owed by Victim to Defendant. The victim told her mother, with whom she lived, that she was leaving the house to run some errands. When she did not return, the victim's mother reported her disappearance to the Missing Persons Unit of the Pittsburgh Police Department. Six months later, her decomposed remains were found under moldy clothing and other debris in the basement of a house in the Spring Garden section of Pittsburgh in which Michael Benintend, one of the prosecution’s primary witnesses, resided during the relevant time period. The issue this case presented for the Supreme Court's review centered on the Missing Persons Unit detective’s testimony and the prosecutor’s closing arguments regarding the early days of the investigation into the victim's disappearance. Following a lead that Defendant was holding the victim against her will, the Missing Persons Unit detective assigned to the case went to Defendant’s house two days after Victim’s disappearance. Pamela Deloe, another prosecution witness, answered the door and asserted that neither the victim nor Defendant were at the house. Accordingly, the detective left her card and asked that Defendant call her. Later that day, Defendant called the detective. The detective then inquired as to when Defendant had last seen the victim. He initially responded that he had not seen her for a year and a half, but then he immediately contradicted his statement, claiming instead that he had not seen her for three months. Subsequent to this contradiction, the detective testified that she asked him to come to the police station to speak to her and he refused. The Supreme Court granted review in this case to consider whether a defendant’s right against self-incrimination is violated when the prosecution utilizes a non-testifying defendant’s pre-arrest silence as substantive evidence of guilt. This was an issue of first impression, to which the United States Supreme Court had not definitively spoken. The Pennsylvania Court agreed with the Superior Court, as well as several sister courts, that the use of pre-arrest silence as substantive evidence of guilt violates a non-testifying defendant’s constitutional rights. The Pennsylvania affirmed the order of the Superior Court remanding for a new trial. However, given that the status of federal jurisprudence was uncertain, the Court based its holding in this case upon the right against self-incrimination set forth in Article I, Section 9 of the Pennsylvania Constitution.
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