Commonwealth of Pennsylvania v. Harold Walker

Summary

The Supreme Court of Pennsylvania held that the trial court did not abuse its discretion by allowing the Commonwealth to ask prospective jurors whether they could follow the principle that an alleged victim's testimony alone, if believed beyond a reasonable doubt, may support a sexual-assault conviction. The Court concluded that the question served the proper purpose of determining whether jurors could follow the law, rather than eliciting their likely verdict based on anticipated facts or testing trial strategy. The Court affirmed Harold Walker's judgment of sentence.

Holdings

1. In a prosecution for a sexual offense under Chapter 31 of the Pennsylvania Crimes Code, a trial court may permit the Commonwealth to ask prospective jurors whether they can follow the legal principle that the alleged victim's testimony, standing alone and if believed, need not be corroborated and may constitute sufficient proof for conviction.
2. The trial court did not abuse its discretion by allowing a voir dire question that contained a legal principle later addressed in the jury instructions, because the question accurately stated the applicable law and did not need to include every qualification or element applicable to the eventual jury charge.

Questions Presented

1. Whether the trial court abused its discretion by permitting the Commonwealth to ask prospective jurors whether they could follow the legal principle that an alleged sexual-assault victim's testimony, standing alone and if believed beyond a reasonable doubt, may support a conviction.
2. Whether the challenged voir dire question was improper because it sought to determine jurors' likely decisions based on anticipated evidence, functioned as a jury instruction, or misstated or incompletely stated Pennsylvania law.

Disposition

affirmed