Com. v. Williams, A.
Com. v. Williams, A. No. 109 MDA 2017
| Pa. Super. Ct. | Jul 31, 2017Background
- Appellant Antoine Shawn Williams was tried for the November 21, 2008 barber‑shop robbery and related killings; a jury convicted him of first‑degree murder (merged with other murder counts for sentencing), robbery, possession of instruments of crime, aggravated assault, and conspiracy. He received life plus 10–20 years.
- Post-conviction appeals and direct appeals were exhausted; the Superior Court affirmed and the Pennsylvania Supreme Court denied allowance of appeal.
- Williams filed a timely pro se PCRA petition raising ineffective‑assistance claims (challenging cross‑examination of a witness and jury instructions).
- Appointed PCRA counsel (Deming) filed a Finley/Turner no‑merit letter and motion to withdraw after reviewing the record and concluding the claims lacked merit; the PCRA court independently reviewed the record and issued a Rule 907 notice of intent to dismiss.
- Due to a docketing error the court initially dismissed without considering Williams’s timely response; after remand and nunc pro tunc relief, the court again denied relief and permitted counsel to withdraw. Williams appealed pro se, asserting among other things that counsel failed to uncover a diminished‑capacity defense and that Martinez v. Ryan applied.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (Commonwealth / PCRA court) | Held |
|---|---|---|---|
| Whether PCRA counsel’s Finley/Turner withdrawal was improper because counsel missed meritorious issues | Deming failed to uncover additional issues of arguable merit (esp. diminished capacity); no‑merit letter inadequate | Deming complied with Turner/Finley; he reviewed the record, listed issues, explained lack of merit; PCRA court independently reviewed and agreed | Court held withdrawal proper; no‑merit letter and independent review satisfied requirements; claim denied |
| Whether the court erred by denying leave to amend the PCRA petition | Williams sought leave to file an amended petition to add claims (including claims against PCRA counsel) | Williams did not identify specific viable additional claims; PCRA court found no basis to allow amendment | Denied — no specific, non‑waived, meritorious claims shown |
| Whether Martinez v. Ryan creates a substantive change entitling collateral relief or excuses procedural defaults in state PCRA proceedings | Martinez permits ineffective‑assistance‑of‑post‑conviction‑counsel to excuse procedural default in federal habeas; Williams argued it entitled relief here | Martinez is a federal habeas rule; this is a state PCRA matter and Martinez is inapposite | Court held Martinez did not apply and denied relief |
| Whether trial counsel was ineffective for failing to pursue a diminished‑capacity defense | Williams contends trial counsel failed to consult and preserve diminished capacity (Dr. Rotenberg report) | Trial counsel sought to introduce the psychiatric report, but diminished capacity requires admission of involvement; Williams maintained innocence so the defense was legally inapplicable | Denied — diminished capacity unavailable where defendant maintains complete innocence; claim frivolous and meritless |
Key Cases Cited
- Finley v. Pennsylvania, 550 A.2d 213 (Pa. Super. 1988) (procedures for counsel withdrawal in post‑conviction cases via no‑merit letter)
- Turner v. Commonwealth, 544 A.2d 927 (Pa. 1988) (court must independently review record when counsel seeks withdrawal)
- Martinez v. Ryan, 566 U.S. 1 (2012) (narrow federal habeas exception allowing ineffective‑assistance‑of‑trial‑counsel claims where initial‑review collateral counsel was absent or ineffective)
- Gibson v. Pennsylvania, 951 A.2d 1110 (Pa. 2008) (explaining diminished‑capacity defense negates specific intent but requires admission of conduct)
- Poplawski v. Commonwealth, 852 A.2d 323 (Pa. Super. 2004) (standard of review for PCRA orders)