Commonwealth v. Kylen Pratt

Summary

The Pennsylvania Superior Court affirmed Kylen Pratt’s judgment of sentence for first-degree murder, possession of an instrument of crime, abuse of a corpse, and tampering with evidence. The court held that a summary of voluminous cell-phone records was properly admitted under Pennsylvania Rules of Evidence 1002 and 1006, that Google searches were relevant and not unfairly prejudicial, and that the consecutive sentences imposed for the non-murder offenses did not constitute an abuse of discretion.

Holdings

1. The trial court properly admitted the detective's summary of the cell-phone records because the records were voluminous, the detective was competent and familiar with the originals, the originals were available to the defense, and the summary complied with Rules 1002 and 1006.
2. The trial court did not abuse its discretion by admitting Pratt's Google searches because the searches were relevant to the Commonwealth's theories concerning motive, state of mind, and consciousness of guilt, and their probative value was not outweighed by unfair prejudice.
3. The aggregate consecutive sentence of four and one-half to nine years imposed for the three non-murder offenses was not manifestly excessive and did not constitute an abuse of discretion.

Questions Presented

1. Whether the trial court properly admitted a detective's chart summarizing voluminous cell-phone timing-advance records under Pennsylvania Rules of Evidence 1002 and 1006.
2. Whether the trial court properly denied a motion in limine seeking to exclude Google searches for male-on-male pornography, sex with dead bodies, and traits of a psychopath.
3. Whether the aggregate consecutive sentences imposed for possession of an instrument of crime, abuse of a corpse, and tampering with evidence constituted an abuse of discretion.

Disposition

affirmed