Death penalty upheld for Point Marion man convicted of beating a child to death
The state Supreme Court on Tuesday upheld the first degree murder conviction and death sentence for Patrick Haney, who was convicted of beating a 4-year-old to death in 2011.
It took jurors under two hours to convict 31-year-old Haney of inflicting the abdominal injuries that killed Trenton St. Clair, his girlfriend’s son, following a two-day trial in March 2014.
Following his conviction, Haney appealed to the state’s high court on the grounds that there was insufficient evidence, among other arguments.
“Viewing the evidence in the light most favorable to the commonwealth, the evidence sufficiently establishes each element of first-degree murder beyond a reasonable doubt,” wrote Justices Correale F. Stevens, Max Baer and Debra McCloskey Todd.
As an element of first-degree murder, the prosecution was required to prove Haney acted with malice and the specific intent to kill, a burden Haney’s court-appointed attorney, Jeremy Davis, argued the prosecution did not meet.
The court disagreed.
“Here, (Haney)’s repeated attacks on 4-year-old Trenton during which he inflicted blows to vital parts of Trenton’s body, such as his head and stomach, over a period of at least three days, and his refusal to allow Trenton to receive timely medical attention while the child endured lasting effects of (Haney)’s abuse, proved beyond a reasonable doubt that (Haney) acted with malice and specific intent to kill,” the justices found.
The judges noted that Haney has not disputed that St. Clair died from his injuries, but that he denies having caused those injuries. Davis argued in the appeal that the only evidence presented at trial that linked Haney to the abuse came from the child’s mother, Heather Forsythe, and Davis contended her testimony was not credible.
According to court records, Assistant District Attorney Mark Mehalov countered by saying there’s no merit in the argument that Forsythe was not credible, because “determinations of credibility are within the sole purview of the jury as finder of fact,” and a jury found her testimony credible at trial.
Beyond Forsythe’s testimony, which included allegations that she had been finding bruising on her son for days leading up to his death and that she had come home to find Haney hitting her son in that timeframe as well, the judges stated, the commonwealth proved through the testimony of two physicians and a state police officer that sufficiently proved Haney was the abuser.
Haney’s appeal also asked the court to determine whether the commonwealth proved torture as an aggravating factor necessary for imposing the death penalty.
The justices, reviewing the record, stated they found ample evidence St. Clair was tortured.
Court documents show testimony from two physicians who treated St. Clair when his lifeless body was brought to Ruby Memorial Hospital by Haney and Forsythe. The doctors described to the jury bruises covering a substantial portion of St. Clair’s body, which were of different ages, suggesting the abuse occurred over a period of time, the Supreme Court noted.
The doctors also testified the abuse was severe enough to cause internal injuries, and that the child would have been experiencing painful symptoms, including severe abdominal pain, fever, lethargy, nausea, vomiting, and increased urine output in the days leading to his death.
“Moreover if Haney wished to simply kill Trenton, a four-year-old child, he easily could have done so,” the justices pointed out. “Instead . . . Trenton sustained injuries to vital and non-vital parts of the body that were distinct from the blow to his abdomen which caused the peritonitis, indicating that (Haney) sought to cause Trenton additional pain and suffering.”
Davis additionally raised the issue of whether or not photographs of St. Clair’s body as depicted at the hospital should have been shown to a jury.
In closing arguments at trial, Mehalov told jurors, “There is no better example of malice than what you see in these pictures — hatred. Hardness of heart. Evil.”
The court found that the evidentiary value of the photos outweighed the risk of inflaming the jurors’ passions.
“A crucial portion of (Haney)’s defense at trial was that Trenton was a clumsy child and many of his bruises were caused by accidental falls,” the justices wrote. “The photographs, while troubling to view, were admissible to explain the nature and extent of Trenton’s injuries. The photographs depict the severity of Appellant’s attacks on Trenton’s four-year-old body and tend to prove that Appellant beat Trenton with the necessary (intent).”
Chief Justice Thomas G. Saylor wrote a dissenting opinion, addressing only the matter of the photos of St. Clair’s body shown to the jury.
Saylor stated he believed “that such graphic, visceral portrayals of dead children create an unacceptable risk of influencing jurors to reach conclusions based on factors other than a strict application of the law to the facts.”
Currently, the Pennsylvania has a moratorium on the death penalty. Gov. Tom Wolf in February halted executions until a report from the Pennsylvania Task Force and Advisory Commission on Capital Punishment is complete, and any recommendations contained in it are satisfactorily addressed.