Com. v. Rogers, P., Com. v. Rogers, P. No. 3356 EDA 2016

Paul Joseph Rodgers was convicted in 1991 of first‑degree murder and a firearms offense; sentenced to life in 1992.
Direct appeals concluded in 1994 when the Pennsylvania Supreme Court denied allowance of appeal; judgment of sentence became final in August 1994.
Rodgers filed multiple PCRA petitions: first (1995) and second denied on the merits; third (2006) dismissed as untimely and affirmed.
On December 20, 2013 Rodgers filed a fourth (successive) pro se PCRA petition asserting newly discovered facts based on an affidavit from Eric Purdy.
The PCRA court dismissed the 2013 petition as untimely; the Superior Court affirmed, concluding the petition was ~18 years late and did not meet the newly‑discovered‑facts exception.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 2013 PCRA petition was timely or met a statutory exception	Rodgers: his incarcerated/indigent status impeded earlier discovery; Purdy affidavit shows newly discovered facts under 42 Pa.C.S. § 9545(b)(1)(ii)	Commonwealth: Judgment became final in 1994; petition filed in 2013 is untimely and Purdy’s affidavit does not present previously unknown facts	Court held petition was untimely and did not satisfy the newly‑discovered‑facts exception; dismissal affirmed

Commonwealth v. Zeigler, 148 A.3d 849 (Pa. Super. 2016) (explains PCRA timeliness rule and statutory exceptions)
Commonwealth v. Abu‑Jamal, 941 A.2d 1263 (Pa. 2008) (newly‑discovered‑facts exception requires facts previously unknown, not just a new source)
Commonwealth v. Bennett, 930 A.2d 1264 (Pa. 2007) (petitioner must show facts were unknown and could not have been ascertained with due diligence)
Commonwealth v. Smallwood, 155 A.3d 1054 (Pa. Super. 2017) (reiterates limitations of newly‑discovered‑facts exception)