Commonwealth v. English
Pennsylvania Supreme Court
446 Pa. 161 (1971)
Facts
William English (defendant) was arguing with Roosevelt English, who was not related to William, about $10 that Roosevelt owed William. William punched Roosevelt in the face, causing Roosevelt to fall and hit his head on the pavement. William searched through Roosevelt’s wallet while Roosevelt was unconscious but did not find any money. Roosevelt died a few days later as a result of his injuries. William was charged with murder. During the trial, the prosecution maintained that William was guilty of felony murder, because he killed Roosevelt during an attempted robbery. William claimed that he never intended to rob Roosevelt, but only to take back his own property that Roosevelt owed him. William requested the trial judge to instruct the jury about this claim-of-right defense. The trial judge did mention this claimed defense at some points, but eventually instructed the jury that even if Roosevelt owed William money, it would still amount to robbery if William tried to take the money by force. William was convicted of voluntary manslaughter. William filed a motion for a new trial based on error in those instructions to the jury, even though he failed to file an exception to the instructions during the trial. William’s motion for a new trial was granted, and the commonwealth appealed.
Rule of Law
Issue
Holding and Reasoning (Bell, C.J.)
Concurrence (Roberts, J.)
Concurrence (Eagen, J.)
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