Commonwealth v. Peters, 473 Pa. 72

Summary

The Supreme Court of Pennsylvania held that the defendant waived his double-jeopardy claim by failing to raise it before his second trial. The court further held that statements and reenactment evidence obtained after authorities made assurances concerning material-witness detention and bail were not shown to result from a knowing, intelligent, and voluntary waiver of Miranda rights. The judgment of sentence was reversed and a new trial was granted.

Holdings

1. Under the circumstances presented, failure to plead double jeopardy before commencement of the second trial waives the claim for appellate review.
2. Peters's first statement was admissible because he was not subjected to custodial interrogation and Miranda warnings were not required.
3. The March 1971 statement, reenactment evidence, and subsequent statement should have been suppressed because the Commonwealth failed to prove that Peters voluntarily waived his Miranda rights.

Questions Presented

1. Whether Peters waived his double-jeopardy claim by failing to plead it before the second trial.
2. Whether Peters's 1969 statement was obtained during custodial interrogation requiring Miranda warnings.
3. Whether the Commonwealth proved that Peters knowingly, intelligently, and voluntarily waived his rights before the March 1971 statement, reenactment, and later statement.
4. Whether the accomplice instruction was erroneous.

Disposition

reversed_and_remanded