The factual history of this case was set forth in greater detail in our prior opinion issued in Appellant's direct appeal. SeeCommonwealth v. Parrish , 621 Pa. 210, 77 A.3d 557 (2013). Sidney had recently undergone a heart transplant, and he required anti-rejection medications, which Victoria administered to him at approximately 8 p.m. each night.
In 2013, this Court affirmed his judgment of sentence. Commonwealth v. Parrish, 621 Pa. 210, 77 A.3d 557 (2013) (Parrish I). In 2014, Parrish timely filed a petition pursuant to the Post Conviction Relief Act (PCRA), 42 Pa. C.S. §§ 9541-9546, in the Court of Common Pleas of Monroe County (PCRA court).
Miranda v. Arizona , 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966). Id . at 684-85 (citing Commonwealth v. Parrish , 621 Pa. 210, 77 A.3d 557, 560 (2013) (automatic review opinion)). Prosecutors charged Parrish with two counts of first-degree murder, 18 Pa.C.S. § 2502(a).
Following his convictions for first degree murder and related counts, petitioner was sentenced to death on May 15, 2012, in the Court of Common Pleas of Monroe County, Pennsylvania. (Doc. 21.) Petitioner's convictions and sentence of death were affirmed by the Pennsylvania Supreme Court on September 25, 2013. See Commonwealth v. Parrish, 77 A.3d 557 (Pa. 2013), rearg. denied, No. 661 Cap. App. Dkt. (Pa. Nov. 27, 2013). His petition for certiorari review was denied by the United States Supreme Court on May 19, 2014. Parrish v. Pennsylvania, No. 13-9201, Order (U.S. May 19, 2014).
Although Appellant's challenge to the sufficiency of the evidence focuses exclusively on whether the evidence was sufficient to prove that he acted with malice, it is this Court's well established practice in direct appeals from the imposition of a sentence of death to review the sufficiency of the evidence presented with respect to each of the elements necessary to sustain a first-degree murder conviction. See Commonwealth v. Parrish, 621 Pa. 210, 77 A.3d 557, 561 (2013). In so doing, we determine “whether the evidence admitted at trial, and all the reasonable inferences derived therefrom viewed in favor of the Commonwealth as verdict winner, supports the jury's finding of all the elements of the offense beyond a reasonable doubt.”
Our Supreme Court has held that in order to convict a defendant of first-degree murder, the Commonwealth must prove, inter alia, that "the defendant acted with malice and the specific intent to kill." Commonwealth v. Parrish, 77 A.3d 557, 561 (Pa. 2013) (citations omitted).
We note at the outset the well-settled principle that the severity or notoriety of the crime charged is immaterial to the application of the legal test. See, e.g., Commonwealth v. Parrish, ––– Pa. –––– & n. 2, 77 A.3d 557, 560–61 & n. 2 (2013) (plea withdrawal granted in capital murder case; appellant convicted at trial of killing girlfriend and their 19-month-old son). By way of contrast, we apply a much more exacting standard when the defendant moves to withdraw his guilty plea following the imposition of sentence.