Com. v. Williams, C.
3228 EDA 2023
| Pa. Super. Ct. | Apr 14, 2025Background
- Christian Williams was convicted by a jury in Philadelphia of several offenses, including involuntary deviate sexual intercourse with a child, unlawful contact with a minor, endangering the welfare of children, and related charges, based on allegations of sexual abuse.
- Williams was sentenced to 10-20 years for IDSI, 2.5-5 years for unlawful contact (concurrent), and other probations/concurrent sentences, totaling an aggregate below guideline sentences.
- Williams challenged the effectiveness of trial counsel under the Post Conviction Relief Act (PCRA), alleging poor advice regarding plea offers and other trial issues.
- Specifically, Williams claimed his lawyer failed to advise him to accept a purported plea offer of 11½-23 months’ imprisonment, advising instead to proceed to trial on misplaced confidence in defeating the charges.
- The PCRA court denied relief without a hearing; Williams appealed. The Superior Court reviewed whether further proceedings were needed, given the dispute over the existence and communication of the more favorable plea offer.
- The appellate court found that an evidentiary hearing was necessary on the plea offer advice allegation and remanded for that limited purpose, but rejected Williams’ other claims of ineffective assistance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance in plea advice | Counsel failed to properly advise on a favorable plea offer, resulting in its rejection. | No evidence such favorable offer (11½-23 months) was conveyed; only a higher offer (6½-13 years) exists in record. | Remanded for evidentiary hearing on this claim only. |
| Failure to move for reconsideration of sentence | Counsel was ineffective for not challenging the sentence as excessive. | Counsel did file a post-sentence motion and sentence was below guidelines and reasonable. | Court found no merit; claim rejected. |
| Failure to cross-examine and present defense evidence | Counsel did not effectively cross-examine or present key evidence/witnesses per Williams’ requests. | Evidence/witnesses not materially affecting outcome; claims undeveloped; procedural requirements not met. | Court found no merit; claim rejected. |
| Denial of PCRA hearing | Erroneous denial of evidentiary hearing on all ineffective assistance claims. | Hearing was unwarranted except possibly on the plea advice issue. | Moot (hearing now ordered on plea advice issue). |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-part standard for ineffective assistance: deficient performance and prejudice)
- Lafler v. Cooper, 566 U.S. 156 (2012) (extends right to effective assistance to plea bargaining)
- Missouri v. Frye, 566 U.S. 134 (2012) (effective assistance required in communicating plea offers)
- Commonwealth v. Spotz, 896 A.2d 1191 (Pa. 2006) (failure to present cumulative evidence is not prejudicial)
- Commonwealth v. Spiewack, 617 A.2d 696 (Pa. 1992) (relevance standard for evidence in criminal trial)
- Commonwealth v. Washington, 927 A.2d 586 (Pa. 2007) (standards for ineffective assistance based on failure to call witnesses)
- Commonwealth v. Elliot, 80 A.3d 415 (Pa. 2013) (petitioner must show unpresented evidence would have changed outcome)