Com. v. Smith, J., Com. v. Smith, J. No. 1103 EDA 2016

Jamal L. Smith, a deaf/hard-of-hearing defendant with cognitive impairments, was convicted after a four-day jury trial of second-degree murder, robbery, and possessing an instrument of crime for the stabbing death of John Reil; he received life without parole.
Police recovered a victim with multiple stab wounds; autopsy showed numerous deep, fatal wounds. DNA and bloodstain evidence tied the victim to a maroon thermal shirt found at Smith’s grandmother’s home; Smith’s prints were found on the vehicle.
Smith gave a detailed July 18, 2009 statement to police describing a struggle in which he stabbed the victim after the victim allegedly tried to stab him; at trial Smith denied the killing and implicated another person (Corey Talley).
Post-conviction, Smith filed a PCRA petition alleging trial counsel were ineffective for (1) failing to present a self-defense theory based on Smith’s pretrial statement and (2) failing to remove alleged undue family influence that prevented Smith from asserting self-defense.
At PCRA evidentiary hearings, trial counsel testified Smith denied responsibility pretrial and maintained the Talley story; Smith later admitted at the PCRA hearing he lied at trial. The PCRA court denied relief; Smith appealed and PCRA counsel filed a Turner/Finley no-merit letter and sought to withdraw.

Issue	Smith's Argument	Commonwealth/Trial Counsel Argument	Held
Whether trial counsel were ineffective for not presenting a self-defense theory based on Smith’s police statement that the victim tried to rob/stab him	Counsel failed to present self-defense despite Smith having told counsel pretrial he stabbed the victim in self-defense	Counsel had a reasonable strategic basis: Smith consistently denied responsibility to counsel and asserted another person committed the murder; presenting self-defense conflicted with Smith’s trial testimony and strategy	Denied — no ineffective assistance: counsel reasonably relied on defendant’s denial and, even if raised, self-defense would not have changed the outcome given overwhelming evidence
Whether trial counsel were ineffective for failing to discover/remove undue family influence that allegedly coerced Smith into avoiding a self-defense defense	Smith’s mother threatened him and incentivized him to lie, preventing counsel from presenting self-defense	No evidence corroborated the family-coercion allegations; counsel testified mother did not direct trial testimony and Smith still denied responsibility when alone with counsel	Denied — claim lacked evidence; PCRA court credited counsel’s testimony over Smith’s assertions

Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988) (establishes counsel-withdrawal/no-merit procedures in PCRA appeals)
Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (applies and refines Anders/Turner withdrawal procedures in post-conviction context)
Commonwealth v. Rykard, 55 A.3d 1177 (Pa. Super. 2012) (describes requirements for no‑merit letter and court’s independent review)
Commonwealth v. Melendez–Negron, 123 A.3d 1087 (Pa. Super. 2015) (standard of review for PCRA denial)
Commonwealth v. Kimball, 724 A.2d 326 (Pa. 1999) (sets out three-prong ineffective-assistance test used in PCRA claims)
Commonwealth v. Steckley, 128 A.3d 826 (Pa. Super. 2015) (presumption of counsel effectiveness; petitioner’s burden at PCRA)
Commonwealth v. Roane, 142 A.3d 79 (Pa. Super. 2016) (trial court credibility findings binding when supported by record)
Commonwealth v. Paddy, 15 A.3d 431 (Pa. 2011) (articulates Pierce three-prong test and review principles for counsel ineffectiveness)
Commonwealth v. Pierce, 527 A.2d 973 (Pa. 1987) (establishes the three-prong test for ineffective assistance of counsel)