Com. v. Williams, A., Jr.
2075 MDA 2016
| Pa. Super. Ct. | Oct 19, 2017Background
- Aaron S. Williams Jr. pleaded guilty (Sept. 8, 2014) to possession with intent to deliver and related charges across two Dauphin County dockets pursuant to a negotiated aggregate sentence (agreed overall range given at plea; sentencing set for Oct. 10, 2014).
- At plea counsel and in discovery the Commonwealth had indicated possible mandatory minimum exposure under 42 Pa.C.S. § 9712.1 and 18 Pa.C.S. § 7508; Williams later claimed counsel told him he faced two separate five-to-ten year mandatory minimums if he did not plead.
- At sentencing the court imposed 4.5 to 10 years; the record does not explain how the 4.5 year minimum was derived or what plea-counsel advice produced that minimum.
- Williams filed a timely PCRA petition alleging plea counsel was ineffective for providing erroneous advice about mandatory minima (thereby inducing an involuntary plea) and that counsel failed to move to suppress evidence; he later amended to add that PCRA counsel’s Turner/Finley no-merit procedures were deficient.
- The PCRA court dismissed Williams’s petition without an evidentiary hearing; Williams appealed. The Superior Court vacated and remanded for an evidentiary hearing, finding genuine factual issues as to whether counsel’s allegedly erroneous advice about mandatory minimums induced an unknowing/involuntary plea and as to PCRA counsel’s Turner/Finley handling.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (Commonwealth/PCRA court) | Held |
|---|---|---|---|
| 1. Whether dismissal without evidentiary hearing was proper | Trial counsel gave erroneous advice about mandatory minimum exposure; this induced an involuntary plea and raises facts outside the record requiring a hearing | The plea colloquy and record show the plea was knowing, voluntary, and the sentence legal, so no hearing needed | Vacated and remanded for an evidentiary hearing on plea inducement claim (court found genuine factual dispute) |
| 2. Whether counsel was ineffective for advising Williams he faced two 5–10 year mandatory minima (inducing plea) | Counsel misadvised re § 9712.1 and § 7508 mandatory minima (some authorities had already called those statutes unconstitutional under Alleyne), so Williams would not have pled but for that advice | The imposed sentence (4.5–10) did not exceed lawful maximum and plea was knowing; thus no relief warranted | Remanded for evidentiary hearing to determine whether counsel’s advice caused an involuntary plea (potential prejudice shown) |
| 3. Whether counsel was ineffective for failing to move to suppress evidence | Counsel failed to seek suppression of allegedly illegally obtained evidence, rendering the plea involuntary because Williams did not know he could raise suppression | The plea waiver and record preclude collateral attack absent manifest injustice; no hearing was warranted | Court declined to rule on the suppression claim on appeal (remanded only on issues 1 & 4); evidentiary hearing may also consider related factual issues |
| 4. Whether PCRA counsel was ineffective in Turner/Finley no‑merit handling | PCRA counsel’s no‑merit letter and decision to seek withdrawal did not comply with Turner/Finley and failed to investigate the legality of sentences; thus Williams was prejudiced | PCRA court relied on its prior ruling and concluded no merit to claims | Vacated and remanded — the Superior Court held the PCRA court erred by not addressing the amended claim of PCRA counsel ineffectiveness and ordered an evidentiary hearing to resolve factual disputes |
Key Cases Cited
- Commonwealth v. Newman, 99 A.3d 86 (Pa. Super. 2014) (en banc) (declaring § 9712.1 unconstitutional post-Alleyne)
- Commonwealth v. Fennell, 105 A.3d 13 (Pa. Super. 2014) (holding § 7508 mandatory minimums infirm under Alleyne reasoning)
- Commonwealth v. Mosley, 114 A.3d 1072 (Pa. 2015) (addressing constitutionality of § 7508 mandatory minima)
- Alleyne v. United States, 570 U.S. 99 (2013) (holding facts that increase mandatory minimums must be submitted to jury and proven beyond reasonable doubt)
- Commonwealth v. Paddy, 15 A.3d 431 (Pa. 2011) (standards for when an evidentiary hearing is required on collateral review)
- Commonwealth v. Prendes, 97 A.3d 337 (Pa. Super. 2014) (requirements for valid guilty plea; manifest injustice standard)