Com. v. Edwards, D.
1917 EDA 2016
| Pa. Super. Ct. | Sep 27, 2017Background
- In 2007 Edwards and accomplices entered an apartment; Edwards and another shot and killed three victims.
- He was arrested in 2010 and charged with three counts of first-degree murder and three counts of conspiracy; the Commonwealth had sought the death penalty.
- Edwards waived a jury trial in a deal where the Commonwealth forewent the death penalty; in 2011 the court convicted him of three counts of first-degree murder and three counts of conspiracy and imposed three consecutive life sentences.
- Edwards’s direct appeal was affirmed and his petition to the Pennsylvania Supreme Court was denied.
- He filed a timely PCRA petition (2014); after hearings the PCRA court denied relief (June 2, 2015). Edwards pursued pro se appellate proceedings; new counsel was appointed, withdrawn after a Grazier hearing, and Edwards proceeded pro se.
- The Superior Court found Edwards’s appellate brief failed to develop his claims (largely ineffective-assistance claims) and denied his application to amend the brief; it affirmed the PCRA denial.
Issues
| Issue | Plaintiff's Argument (Edwards) | Defendant's Argument (Commonwealth/PCRA court) | Held |
|---|---|---|---|
| Whether trial counsel was ineffective for failures in mitigation investigation and witness investigation | Counsel failed to investigate mitigation and potential witnesses (Torres, Christine, Thompson letter) causing prejudice | Counsel’s performance had reasonable strategic bases; claims lacked proof under the three-prong ineffectiveness test | Denied — claims waived on appeal for inadequate briefing and unsupported by record |
| Whether appellate/"appeal" counsel was ineffective | Appellate counsel failed to raise/argue issues effectively | No persuasive developed argument; performance presumed effective absent proof | Denied — waived for failure to develop issues; no merit shown |
| Whether prosecutorial misconduct occurred regarding witness information (Josh Oliver) | Commonwealth withheld/misused witness information in violation of due process | No developed argument or record support presented on appeal | Denied — claim waived and not shown on record |
| Whether the Superior Court should permit brief amendment after initial deficient brief | Edwards sought to file an amended brief containing arguments | Commonwealth opposed; court reviewed application | Denied — amendment refused; even if allowed, claims still waived or inadequately supported |
Key Cases Cited
- Commonwealth v. Rivera, 10 A.3d 1276 (Pa. Super. 2010) (ineffective-assistance presumption and burden on appellant)
- Commonwealth v. Fulton, 830 A.2d 567 (Pa. 2003) (three-prong test for ineffective assistance of counsel)
- Commonwealth v. Jones, 811 A.2d 994 (Pa. 2002) (failure to satisfy any prong defeats ineffectiveness claim)
- Commonwealth v. Quaranibal, 763 A.2d 941 (Pa. Super. 2000) (PCRA standard of review and dismissal without hearing when claims lack support)
- Commonwealth v. Johnson, 985 A.2d 915 (Pa. 2009) (claims inadequately briefed or undeveloped are waived)
- Commonwealth v. Rivera, 685 A.2d 1011 (Pa. Super. 1996) (pro se litigant not entitled to special advantage; court will not become appellant’s counsel)
- Commonwealth v. Grazier, 713 A.2d 81 (Pa. 1998) (procedures for permitting a defendant to proceed pro se)