## Facts

- Hayley Twinn left her two-year-old son, Jaques, and an infant daughter in Aric Shayne Woodard’s care on November 6, 2011, and did not return that day.
- On November 7, 2011, Woodard angrily warned a neighbor that Hayley “better come get her children or she would be sorry.”
- Police responded to a report of a two-year-old in cardiac arrest and found Woodard holding Jaques, who was wet, naked, and smelled strongly of feces.
- Jaques was transported to a hospital and pronounced dead.
- Woodard told authorities Jaques had defecated and smeared feces; Woodard said he “popped” the child, pulled him by the ear, sent him to bathe, and later found him unresponsive in the bathtub.
- Medical evidence documented extensive injuries and trauma inconsistent with accidental drowning and consistent with severe beating.
- At trial, the Commonwealth introduced multiple autopsy photographs to illustrate expert testimony and to rebut Woodard’s claim that Jaques drowned.

## Issues

1. Whether the trial court abused its discretion, or denied due process, by admitting multiple graphic autopsy photographs during the guilt phase.
2. Whether the evidence was sufficient to support a conviction for first-degree murder.
3. Whether asserted guilt- and penalty-phase errors required reversal of the convictions or the death sentence.

## Decision

- The Pennsylvania Supreme Court affirmed Woodard’s convictions and the judgment of sentence of death.
- The court held the trial court did not abuse its discretion in admitting the autopsy photographs.
- The court concluded the photographs served a valid evidentiary purpose on disputed issues concerning cause and manner of death and did not render the trial fundamentally unfair.
- The court rejected Woodard’s remaining claims, including challenges to the sufficiency of the evidence and to aspects of the penalty phase.

## Legal Principles

- Gruesome crime-scene or autopsy photographs are not per se inadmissible; admissibility turns on relevance and whether probative value is outweighed by the danger of inflaming the jury’s passions.
- Autopsy photographs may be admitted to illustrate and help the jury evaluate medical or forensic testimony, including the nature, extent, and distribution of injuries.
- When a defendant advances an alternative cause of death, photographs may be especially probative to rebut that theory.
- Trial courts have substantial discretion to select and limit photographs to avoid cumulative or gratuitously inflammatory presentation.
- A due process violation requires more than disturbing evidence; the challenged admission must render the trial fundamentally unfair.

## Conclusion

The court upheld the guilt-phase admission of autopsy photographs because they materially assisted the jury in understanding expert testimony and resolving the contested cause of death, and it affirmed the first-degree murder conviction and death sentence.


Commonwealth v. Woodard, 129 A.3d 480 (Pa. 2015)