Satterwhite v. Commonwealth

KELSEY, Judge.

Dominic Joyner was shot four times at close range. As he faded in and out of consciousness, he identified the shooter as Darin Satterwhite. Joyner later died from gunshot wounds. A jury found Satterwhite guilty of murdering Joyner. At trial and on appeal, Satterwhite argues the victim’s statements were inadmissible both under state evidentiary and federal constitutional law because the victim was not present at trial and thus was unavailable for cross-examination. Affirming the trial court, we hold Joyner’s statements constituted dying declarations admissible under the common…