Com. v. Watley, J.
Com. v. Watley, J. No. 1545 WDA 2016
| Pa. Super. Ct. | Apr 17, 2017Background
- Jamel Watley was convicted in 1993 of first‑degree murder and related offenses for a 1993 killing and was sentenced to life without parole. His judgment of sentence became final in 1997.
- Watley filed multiple PCRA petitions: a timely one in 1998 (denied), subsequent petitions in 2006, 2010, and 2012 (all dismissed as untimely), and the instant fifth petition filed March 22, 2016.
- Appointed counsel filed a Turner/Finley no‑merit letter; the PCRA court issued Rule 907 notice, received Watley’s response, and dismissed the 2016 petition as untimely on September 22, 2016. Watley appealed pro se.
- Watley argued his life‑without‑parole sentence is unconstitutional under Miller v. Alabama and Montgomery v. Louisiana, asserting he should be treated like juveniles because brain development continues into the mid‑twenties.
- The PCRA court and this Court analyzed timeliness under 42 Pa.C.S. § 9545, concluding the petition was untimely and that Miller/Montgomery do not apply to offenders older than 18.
Issues
| Issue | Watley’s Argument | Commonwealth’s Argument | Held |
|---|---|---|---|
| Timeliness / PCRA jurisdiction | Petition is timely under the Miller/Montgomery newly recognized‑right exception | Petition is facially untimely; no statutory exception pleaded or proven | Petition untimely; PCRA court lacked jurisdiction to reach merits |
| Eighth Amendment — Miller applicable to older young adults | Miller’s reasoning re: developmental immaturity extends to persons in their early‑to‑mid‑20s; Watley was 20 at offense | Miller applies only to juvenile offenders under 18; cannot be extended to adults | Miller not available to offenders older than 18; Watley cannot rely on it for §9545(b)(1)(iii) exception |
| Eighth Amendment — mandatory LWOP for adults convicted of murder | Mandatory LWOP is unconstitutional for young adults | Mandatory LWOP for adults remains lawful absent Miller’s juvenile rule | Claim not cognizable via Miller; court did not reach merits because of timeliness bar |
| Fourteenth Amendment — equal protection challenge to LWOP | Disparate treatment of young adults vs juveniles violates equal protection | No valid time‑bar exception; merits not reached | Equal protection claim not considered due to untimeliness |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (held mandatory life without parole unconstitutional for juvenile homicide offenders)
- Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller announced a new substantive rule that is retroactive on collateral review)
- Commonwealth v. Robinson, 139 A.3d 178 (Pa. Super. 2016) (PCRA timeliness is jurisdictional and exceptions are statutory)
- Commonwealth v. Furgess, 149 A.3d 90 (Pa. Super. 2016) (Miller does not apply to offenders older than eighteen)
- Commonwealth v. Jackson, 30 A.3d 516 (Pa. Super. 2011) (untimely PCRA petitions without pleaded exceptions must be dismissed)
- Commonwealth v. Brown, 143 A.3d 418 (Pa. Super. 2016) (standard of review for PCRA denials)