Com. v. Eades, D.
Com. v. Eades, D. No. 3544 EDA 2015
| Pa. Super. Ct. | May 19, 2017Background
- Darren Eades was convicted in 1996 of first‑degree murder, robbery, burglary, and PIC; received life for murder and additional aggregate terms on other counts. Appeals and multiple PCRA petitions were previously litigated and denied.
- In 2012 Eades requested a copy of his sentencing order from the DOC under the RTKL; DOC responded it did not possess the sentencing order.
- In 2013 Eades filed writs of habeas corpus ad subjiciendum arguing DOC lacked authority to detain him without possession of a written sentencing order.
- Pennsylvania Supreme Court directed the lower court to address his petitions; the trial court denied habeas relief in November 2015.
- Eades appealed, arguing (1) the court erred by denying an evidentiary hearing, (2) the court misapplied Joseph v. Glunt and §9764(a)(8), and (3) the court should have issued an order to show cause.
Issues
| Issue | Eades's Argument | Commonwealth/DOC's Argument | Held |
|---|---|---|---|
| Whether DOC may lawfully detain Eades without a copy of the written sentencing order | DOC must possess a sentencing order per 42 Pa.C.S. § 9764(a)(8); absence renders confinement unlawful | §9764 governs transfer procedures and records transmission, not DOC’s authority to detain a duly sentenced prisoner | Denied — §9764 does not create a prisoner remedy; detention lawful based on sentencing record (notes of testimony, docket, quarter sessions file) |
| Whether the habeas court erred by not holding an evidentiary hearing | A hearing was required to resolve factual dispute about DOC’s possession/authority | No hearing required where record (certified sentencing materials) refutes petitioner and no prima facie case exists | Denied — hearing unnecessary because the record refuted Eades’s claim |
| Whether the court should have issued a rule to show cause before denying the writ | Court should have ordered the DOC to show cause why confinement was lawful | A rule to show cause is not required when the record refutes the petition or petitioner fails to make a prima facie case | Denied — rule to show cause not required under these circumstances |
Key Cases Cited
- Joseph v. Glunt, 96 A.3d 365 (Pa. Super. 2014) (§9764 governs transfer/recording procedures and does not create a detention‑remedy for prisoners)
- Rivera v. Pennsylvania Dep’t of Corrections, 837 A.2d 525 (Pa. Super. 2003) (standard of review for habeas denial is abuse of discretion)
- Eades v. Philadelphia Common Pleas Courts, 123 A.3d 775 (Pa. 2015) (Supreme Court directed lower court to address petitioner’s habeas petitions)
- Commonwealth ex rel. Rogers v. Claudy, 90 A.2d 382 (Pa. Super. 1952) (no rule to show cause or hearing required when record refutes petition)
- Commonwealth ex rel. De Poe v. Ashe, 74 A.2d 767 (Pa. Super. 1950) (same)