Com. v. Williams, C.
1956 MDA 2015
| Pa. Super. Ct. | Aug 24, 2016Background
- Corey L. Williams was convicted in 2003 of robbery, unlawful restraint, receiving stolen property, conspiracy, and carrying a firearm without a license; he received an aggregate sentence of 8½ to 35 years.
- Direct appeals concluded in 2007 when the Pennsylvania Supreme Court denied further review; the judgment of sentence became final on February 27, 2007.
- Williams filed a prior pro se PCRA petition (2008), amended, litigated, and denied; this Court affirmed denial in 2012.
- On July 13, 2015, Williams filed the present (second/successive) PCRA petition raising many challenges to his sentencing and alleged statutory/ Superior Court order violations.
- The PCRA court issued a Rule 907 notice and dismissed the petition on September 3, 2015 for lack of jurisdiction because the petition was untimely and Williams did not plead any statutory time‑bar exception.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (Commonwealth/Trial Court) | Held |
|---|---|---|---|
| Timeliness / jurisdiction of PCRA petition | Williams argued merits of multiple sentencing and statutory violations (failure to follow Superior Court order, statutory sentencing rules, excessive/consecutive sentence). | Commonwealth argued petition was filed in 2015, long after finality (2007), and Williams failed to plead any statutory exception to the one‑year PCRA time bar. | Court held petition was patently untimely and dismissed for lack of jurisdiction. |
| Applicability of prior Superior Court order | Williams claimed this Court’s prior order required vacatur of his sentence at this docket. | Commonwealth/trial court: the prior order (82 MDA 2014) applied to a different docket (No. 511) and did not affect the separate judgment at No. 432. | Court held Williams’ contention was without merit; prior order did not affect this judgment. |
| Alleged statutory sentencing errors (aggregation / consecutive sentences) | Williams argued the court/DA failed to follow statutes regarding aggregation, consecutive sentencing, and record of reasons for sentence. | Commonwealth/trial court focused on procedural default—these claims were raised too late and no time‑bar exception was pled. | Court did not reach merits due to lack of jurisdiction; claims dismissed. |
| Claims of excessive sentence / failure to consider rehabilitation | Williams argued sentence was excessive and rehabilitative needs were ignored. | Commonwealth/trial court: substantive sentencing claims are barred by untimeliness absent an exception. | Court dismissed the claims as untimely and outside PCRA court jurisdiction. |
Key Cases Cited
- Commonwealth v. Williams, 35 A.3d 44 (Pa. Super. 2011) (timeliness and jurisdiction principles for PCRA review)
- Commonwealth v. Watts, 23 A.3d 980 (Pa. 2011) (PCRA time‑bar cannot be circumvented by equitable exceptions)
- Commonwealth v. Monaco, 996 A.2d 1076 (Pa. Super. 2010) (judgment is final at conclusion of direct review or expiration of time for seeking review; one‑year filing rule explained)