Commonwealth v. Hardy

The defendant was convicted by a jury of murder in the first degree by reason of deliberate premeditation and extreme atrocity or cruelty.1 Represented on appeal by trial counsel, the defendant argues that the following were prejudicial error: (1) the denial of his motion for a mistrial after jurors heard comments from spectators while on a view; (2) the late disclosure of evidence by the prosecution; (3) the admission of the codefendants’ confessions after severance; (4) the instruction to the jury on consciousness of guilt and the failure to give a “Bowden instruction” (see Commonwealth v.…