Com. v. Sims, R.
1560 MDA 2024
| Pa. Super. Ct. | Jun 30, 2025Background
- Roderick Sims was convicted in 2008 for the murder of Charity Sprickler, burglary, and terroristic threats after a trial, and sentenced to life imprisonment in 2012.
- Sims' conviction and sentence were affirmed on direct appeal, with the Pennsylvania Supreme Court denying further review in 2014.
- Sims filed multiple (six) PCRA petitions. Each subsequent petition raised similar Brady and ineffective assistance claims, and was found untimely.
- Sims has long alleged that destroyed blood samples constituted a Brady violation and would have shown intoxication and lack of criminal intent.
- All petitions, including the current (sixth), were dismissed as untimely because Sims failed to plead or prove any statutory exceptions to the one-year time bar.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of PCRA petition | Sims: Governmental interference, Brady claim, miscarriage | Commonwealth: Petition is untimely, no exception applies | Petition was untimely; no exception satisfied |
| Destruction of blood samples (Brady violation) | Sims: Destroyed evidence exonerates him | Commonwealth: Claim previously raised, no new facts | Duplicative, not new; not jurisdictional |
| Denial of speedy trial and Batson/EPC jury claim | Sims: Jury selection and delays violated rights | Commonwealth: Claims untimely and unsupported | Untimely, not pleaded/proved properly |
| Ineffective assistance (failure to call witnesses, etc.) | Sims: Counsel failed to subpoena, denied fair trial | Commonwealth: Ineffective assistance claim doesn't except bar | Ineffectiveness alone not exception to bar |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (establishes prosecution’s duty to disclose exculpatory evidence)
- Batson v. Kentucky, 476 U.S. 79 (1986) (prohibits racial discrimination in jury selection)
- Commonwealth v. Marshall, 947 A.2d 714 (Pa. 2008) (petitioner bears burden to prove PCRA timeliness exceptions)
- Commonwealth v. Albrecht, 994 A.2d 1091 (Pa. 2010) (PCRA courts lack jurisdiction over untimely petitions)