Com. v. Patterson, T.
Com. v. Patterson, T. No. 1029 WDA 2016
| Pa. Super. Ct. | Apr 18, 2017Background
- Tyrique Patterson was convicted by jury on June 9, 2003 of third‑degree murder, robbery of a motor vehicle, and criminal trespass and sentenced to 22½ to 45 years on July 22, 2003.
- Direct appeal was denied by this Court on June 4, 2004; Patterson did not seek allowance of appeal to the Pennsylvania Supreme Court, so judgment became final July 6, 2004.
- Over the years Patterson filed multiple PCRA petitions. His most recent pro se PCRA petition was filed May 19, 2016, alleging Brady suppression of criminal records for the victim and a Commonwealth witness (Jacob Hackett) that would support a self‑defense theory.
- Patterson claimed he first received the documentary evidence (criminal records) on April 29, 2016, and therefore invoked the PCRA newly‑discovered‑facts exception (42 Pa.C.S. § 9545(b)(1)(ii)), filing within 60 days.
- The PCRA court issued Pa.R.Crim.P. 907 notice and dismissed the petition on July 1, 2016; Patterson appealed. The Superior Court affirmed, holding the petition untimely and the claims previously litigated.
Issues
| Issue | Patterson's Argument | Commonwealth/PCRA Court's Argument | Held |
|---|---|---|---|
| Timeliness under PCRA §9545(b)(1)(ii) (newly discovered facts) | Patterson: He learned of suppressed criminal records on April 29, 2016 and filed within 60 days, so the exception applies. | Petition was filed well after the judgment became final (2004); the claimed records and suppression were previously raised and the exception is not met. | Court: Petition untimely; §9545(b)(1)(ii) not satisfied. |
| Brady suppression of witness/victim criminal records | Patterson: Commonwealth withheld crimen falsi records of victim and star witness, warranting evidentiary hearing/new trial. | The alleged withholding was previously raised and rejected; record does not support entitlement to relief. | Court: Claim previously litigated and meritless; no relief. |
| Requirement for evidentiary hearing | Patterson: An evidentiary hearing was required because genuine issues of material fact exist. | A hearing may be denied if the claim is frivolous or lacks record support. | Court: No hearing required; petition frivolous/without support. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (suppression of exculpatory evidence violates Due Process)
- Halley v. Commonwealth, 870 A.2d 795 (Pa. 2005) (standard of review for PCRA dismissal)
- Carpenter v. Commonwealth, 725 A.2d 154 (Pa. 1999) (previously litigated/requirements for PCRA relief)
- Hernandez v. Commonwealth, 79 A.3d 649 (Pa. Super. 2013) (timeliness jurisdictional; 60‑day rule for exceptions)
- Jordan v. Commonwealth, 772 A.2d 1011 (Pa. Super. 2001) (PCRA court may deny hearing if claim frivolous)
- Carr v. Commonwealth, 768 A.2d 1164 (Pa. Super. 2001) (review standard for PCRA findings)
- Dickerson v. Commonwealth, 900 A.2d 407 (Pa. Super. 2006) (criminal records must be shown exculpatory to warrant relief)