Com. v. Daniels, E., 539 EDA 2016

Background

In 2009 Daniels and two co-defendants entered an apartment building and robbed Rian Thal and Timothy Gilmore; both victims were shot and killed. Daniels was tried and convicted of two counts of second‑degree murder, robbery, conspiracy (later vacated), and firearms offenses; he received two consecutive life without parole terms.
Daniels filed a pro se PCRA petition in 2014; counsel filed an amended petition alleging trial counsel was ineffective for failing to object to prosecutorial and judicial misconduct and to request mistrials; he sought a new trial or an evidentiary hearing.
The Commonwealth moved to dismiss; the PCRA court issued Rule 907 notice and dismissed the petition without an evidentiary hearing in February 2016 after Daniels did not respond.
The PCRA court reasoned Daniels’ petition relied on boilerplate recitation of the Pierce ineffective‑assistance test and conclusory allegations without pleading facts or applying law to the record to satisfy each Pierce prong, and further concluded the evidence of guilt was overwhelming.
On appeal, Daniels’ brief largely reproduced his amended petition and failed to address the PCRA court’s deficiencies; the Superior Court affirmed dismissal, holding Daniels did not plead or proffer facts to establish a colorable ineffectiveness claim or entitlement to a hearing.

Issues

Issue	Daniels' Argument	Commonwealth/PCRA Court Argument	Held
Whether trial counsel was ineffective for failing to object to prejudicial opening‑statement remarks and seek mistrial	Counsel failed to object to prosecutor’s allegedly prejudicial opening remarks; this deprived Daniels of a fair trial	Petition merely lists instances and cites transcript pages without factual development or legal analysis; boilerplate claims insufficient; evidence was overwhelming	Denied — petition insufficiently pleaded; no relief warranted
Whether trial counsel was ineffective for failing to object to alleged prosecutorial misconduct during trial	Counsel’s omissions allowed prosecutorial misconduct to influence jury	Claims were conclusory, not tied to record or law; no proffer of disputed facts to justify a hearing	Denied — boilerplate allegations fail Pierce test
Whether trial counsel was ineffective for failing to object to judicial error/misconduct	Trial judge’s rulings constituted misconduct warranting mistrial if objected to	Petition did not explain what was improper or how objections would have had a reasonable basis or led to prejudice	Denied — no colorable claim pleaded
Whether an evidentiary hearing was required on Daniels’ PCRA claims	A hearing would allow proof of factual disputes and establish ineffectiveness	Daniels relied on the trial record and offered no proffer of additional facts; hearings are not discovery and require a colorable claim	Denied — no genuine issue of material fact and no proffered evidence

Key Cases Cited

Pierce v. Commonwealth, 527 A.2d 973 (Pa. 1987) (establishes three‑part ineffective assistance test)
Commonwealth v. Reid, 99 A.3d 470 (Pa. 2014) (standards for PCRA hearings and review of dismissals)
Commonwealth v. Paddy, 15 A.3d 431 (Pa. 2011) (boilerplate allegations insufficient to prove ineffectiveness)
Commonwealth v. Steele, 961 A.2d 786 (Pa. 2008) (PCRA petitioner must meaningfully develop Pierce prongs)
Commonwealth v. Sneed, 45 A.3d 1096 (Pa. 2012) (evidentiary hearings reserved for colorable claims raising material factual disputes)