Com. v. Samuels, G.
122 A.3d 1141
Pa. Super. Ct.2015Background
- In 1999 Gregory Samuels shot his girlfriend, Bathsheba Woodall; a jury convicted him of first‑degree murder and PIC, and he received life plus a consecutive term.
- Samuels appealed; appellate affirmance was completed and his judgment became final on February 9, 2005.
- Samuels filed an initial PCRA petition in 2003 (treated as timely after Supreme Court review concluded); that petition was denied and the denial was affirmed on appeal in 2006.
- On April 23, 2012 Samuels filed a second PCRA petition raising claims including juror perjury/fraud, ineffective assistance of counsel, and prosecutorial failure to expose perjury; the PCRA court issued a Pa.R.Crim.P. 907 notice and then dismissed the petition as untimely on August 25, 2014.
- The Superior Court reviewed the dismissal, focusing on the jurisdictional PCRA timeliness rules and whether Samuels pleaded any of the three statutory exceptions to the one‑year filing deadline.
- The Superior Court concluded Samuels failed to plead or prove an exception under 42 Pa.C.S. § 9545(b)(1), affirmed dismissal for lack of jurisdiction, and declined to reach the merits or grant an evidentiary hearing.
Issues
| Issue | Samuels' Argument | Commonwealth/PCRA Court's Argument | Held |
|---|---|---|---|
| Timeliness of second PCRA petition | Petition timely under exceptions: governmental interference and newly discovered facts (juror perjury/fraud) | Petition was filed well after the one‑year deadline and no statutory exception was pleaded or proven | Petition untimely; dismissal affirmed for lack of jurisdiction |
| Entitlement to evidentiary hearing | Court should hold a hearing to develop credibility of alleged statements/facts | No hearing required when petition is patently untimely or lacks support in the record | No hearing; court may decline hearing when claim is frivolous or unsupported |
| Ineffective assistance of counsel | Counsel rendered constitutionally deficient assistance at a critical stage (impacting due process) | Claim is untimely and not properly before the court; merits not reached | Not considered on merits due to untimeliness/jurisdictional bar |
| Prosecutorial failure to expose perjury/judicial misconduct | Prosecutor/judge knew or should have known about juror perjury and failed to act, amounting to fraud on the court | Allegations are conclusory and do not plead the statutory exceptions; untimely | Allegations insufficient to invoke PCRA time‑bar exceptions; dismissal affirmed |
Key Cases Cited
- Freeland v. Commonwealth, 106 A.3d 768 (Pa. Super. 2014) (standard of review for PCRA appeals and evidentiary hearing discretion)
- Miller v. Commonwealth, 102 A.3d 988 (Pa. Super. 2014) (explaining § 9545 time‑bar and requirement to plead statutory exceptions)
- Turner v. Commonwealth, 544 A.2d 927 (Pa. 1988) (no‑merit / counsel withdrawal procedures referenced for PCRA counsel)
- Finley v. Commonwealth, 550 A.2d 213 (Pa. Super. 1988) (procedures for counsel filing a no‑merit letter in collateral proceedings)
- Commonwealth v. Samuels, 863 A.2d 1145 (Pa. 2004) (Supreme Court action referenced in procedural history)