Background

• Derrick Edmunds and a co-defendant shot into a vehicle; Jason Bryan was killed and Kevin Robertson wounded. Edmunds gave an inculpatory statement.
• Edmunds was tried jointly, convicted of first-degree murder and related charges, and sentenced to life without parole plus consecutive terms. This Court previously affirmed his conviction and the Supreme Court denied allowance of appeal.
• Edmunds filed a PCRA petition alleging trial counsel was ineffective for not requesting a "no adverse inference" instruction and for failing to preserve a weight-of-the-evidence claim; the PCRA court initially granted relief on the no-adverse-inference claim.
• This Court vacated the PCRA relief as to the no-adverse-inference instruction and remanded for disposition of the remaining weight/ineffectiveness claim. On remand, the PCRA court denied relief on the weight claim. Edmunds timely appealed.
• The sole issue on appeal is whether trial counsel was ineffective for failing to preserve/challenge the weight of the evidence; the PCRA court found Edmunds failed to show the underlying weight claim had arguable merit.

Issues

Key Cases Cited

• Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-prong standard for ineffective assistance of counsel: deficient performance and prejudice)
• Commonwealth v. Koehler, 36 A.3d 121 (Pa. 2012) (counsel presumed effective; defendant must show both deficiency and prejudice)
• Commonwealth v. Sneed, 45 A.3d 1096 (Pa. 2012) (sets three-prong test for PCRA ineffectiveness claims: arguable merit, no reasonable basis, prejudice)
• Commonwealth v. Pierce, 786 A.2d 203 (Pa. 2001) (further discussion of standards for establishing counsel ineffectiveness in PCRA context)
• Commonwealth v. Edmunds, 998 A.2d 1011 (Pa. Super. 2010) (prior appellate decision affirming Edmunds' convictions)
• Commonwealth v. Perry, 128 A.3d 1285 (Pa. Super. 2015) (appellate review standards for PCRA orders)