Discovery • Sanction • Inculpatory Statements • Disclosure Obligations
Commonwealth v. Maldonodo, PICS Case No. 17-1448 (Pa. Super. Sept. 12, 2017) Bowes, J. (30 pages).
The trial court erred in precluding the commonwealth from offering as evidence two jail call recordings in which defendant allegedly made inculpatory statements as a sanction for failing to fulfill an earlier promise to provide transcriptions of all his recorded phone calls where the scope of the earlier promise was unclear and the bulk of the other recordings immaterial. The court reversed and remanded.
