Commonwealth of Pennsylvania v. Tedor Davido

Summary

The Supreme Court of Pennsylvania affirmed the denial of Tedor Davido’s petition for relief under the Post Conviction Relief Act in a capital case. The opinion addresses claims concerning the warrantless entry and search of Davido’s residence, ineffective assistance of counsel, suppression of evidence, and related constitutional issues.

Holdings

1. The warrantless entry and limited search were objectively reasonable under the totality of the circumstances because officers had a reasonably specific report of domestic violence, promptly arrived at the residence, received no response, and reasonably believed an injured victim might be inside and in need of immediate aid.
2. Davido failed to establish ineffective assistance because he did not prove arguable merit, lack of a reasonable strategic basis, and resulting prejudice as required by Pennsylvania's application of Strickland.
3. Davido was not entitled to relief based on alleged nondisclosure of jailhouse informants' mental-health records because he failed to show that the evidence was material or that either witness's mental condition impaired the ability to observe, recall, or report events.
4. Davido's waivers of counsel and of presenting mitigating evidence were knowing, intelligent, and voluntary, and counsel was not ineffective for honoring those decisions.

Questions Presented

1. Whether trial counsel was ineffective for failing to challenge the warrantless entry and rescue search of Davido's residence.
2. Whether counsel was ineffective regarding the testimony of the forensic pathologist and sexual-assault examiner.
3. Whether the Commonwealth violated Brady by failing to disclose mental-health records of jailhouse informants.
4. Whether counsel was ineffective in investigating and presenting voluntary-manslaughter and mitigation evidence.
5. Whether Davido's waivers of counsel and mitigation evidence during the penalty phase were invalid.
6. Whether alleged procedural and evidentiary errors in the PCRA proceedings warranted relief.

Disposition

affirmed