Com. v. Brooks, W.
973 MDA 2016
| Pa. Super. Ct. | Jan 27, 2017Background
- In 1971 Wayne Eugene Brooks was convicted of first-degree murder and sentenced to life imprisonment under 18 P.S. § 4701; Pennsylvania Supreme Court affirmed in 1973.
- Brooks filed numerous collateral challenges over decades; in 2015 he filed a pro se petition labeled a writ of habeas corpus arguing § 4701 was unconstitutional and seeking resentencing.
- The PCRA court treated the filing as a PCRA petition, issued Rule 907 notice, received a response, and dismissed the petition as untimely in May 2016.
- Brooks appealed; he argued the court erred by converting his habeas petition into a PCRA petition and that Bradley rendered § 4701 invalid so he was entitled to resentencing.
- The Superior Court reviewed whether Brooks’s claim fell within the PCRA’s exclusive collateral-relief framework and whether his petition was time-barred.
- The court concluded Brooks’s sentencing challenge is cognizable under the PCRA, his petition (filed in 2015) was untimely (judgment final in 1974), no timeliness exception was pled, and his challenge to § 4701 is moot because he was not sentenced to death.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether court erred by treating Brooks’s habeas filing as a PCRA petition | Brooks: his claim challenges constitutionality of the statute (Bradley) and is not governed by the PCRA | Commonwealth/PCRA court: PCRA is exclusive remedy for collateral claims that it can remedy | Held: No error — PCRA is the exclusive vehicle for such claims |
| Whether Brooks’s challenge to § 4701 is timely under the PCRA | Brooks: seeks resentencing based on Bradley; implies relief available regardless of timeliness | Commonwealth: petition filed 2015, judgment became final in 1974, petition is untimely and no exception pleaded | Held: Petition is time-barred under 42 Pa.C.S. § 9545(b)(1) |
| Whether a timeliness exception applies | Brooks: did not successfully plead a statutory exception | Commonwealth: no exception alleged or proven; PCRA exceptions not met | Held: No exception shown; court lacked jurisdiction to consider the untimely claim |
| Whether § 4701 challenge is live where defendant received life, not death | Brooks: statute declared unconstitutional (Bradley) so resentencing required | Commonwealth: Bradley addressed death penalty; where no death sentence was imposed, the issue is moot | Held: Challenge to § 4701 is moot as Brooks was not sentenced to death |
Key Cases Cited
- Commonwealth v. Bradley, 449 Pa. 19, 295 A.2d 842 (Pa. 1972) (invalidated the statutory death-penalty scheme then in effect)
- Furman v. Georgia, 408 U.S. 238 (U.S. 1972) (U.S. Supreme Court decision prompting scrutiny of death-penalty statutes)
- Commonwealth v. Pagan, 864 A.2d 1231 (Pa. Super. 2004) (PCRA is the exclusive remedy for collateral claims including habeas corpus)
- Commonwealth v. Peterkin, 722 A.2d 638 (Pa. 1998) (PCRA time limits do not unconstitutionally limit habeas relief)
- Commonwealth v. Mercado, 826 A.2d 897 (Pa. Super. 2003) (labeling a petition habeas cannot evade PCRA timeliness requirements)
- Commonwealth v. Voss, 838 A.2d 795 (Pa. Super. 2003) (PCRA time limits apply to legality-of-sentence claims)
- Commonwealth v. Edwards, 426 A.2d 550 (Pa. 1981) (if no death sentence imposed, invalidity of death statute is moot)