Com. v. Williams, D.
2007 EDA 2015
| Pa. Super. Ct. | Dec 22, 2016Background
- Darnell Williams was convicted by a jury (June 2010) of first‑degree murder, related firearms offenses, and possession of an instrument of crime; sentenced to life without parole plus concurrent shorter terms.
- A prior PCRA petition had been granted to reinstate direct appeal rights; this Court affirmed the convictions on direct appeal in 2012.
- Williams filed the instant PCRA petition on October 25, 2013 raising predominantly ineffective‑assistance‑of‑counsel (IAC) claims and one alleged Brady issue (not briefed on appeal).
- The PCRA court issued a Pa.R.Crim.P. 907 notice and dismissed the petition without an evidentiary hearing on May 29, 2015; Williams timely appealed.
- The Superior Court reviewed whether dismissal without a hearing was proper given Williams’ allegations (failure to seek discovery of images, inadequate cross‑examination of several witnesses, failure to file a suppression motion for an out‑of‑court ID, and failure to pursue an alternate shooter theory).
- The Superior Court affirmed, concluding Williams failed to adequately plead or prove the three Pierce prongs for IAC and that several claims lacked arguable merit or showed no prejudice, obviating the need for a hearing.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (Commonwealth/PCRA court) | Held |
|---|---|---|---|
| Whether PCRA court erred by dismissing petition without an evidentiary hearing | Williams argued he properly pled facts that would entitle him to relief and thus was entitled to a hearing | Commonwealth argued the record showed no genuine material issues; no absolute right to a hearing when claims lack merit or show no prejudice | Court held dismissal without a hearing was proper because claims lacked arguable merit or failed to show prejudice |
| Whether trial counsel was ineffective for failing to request discovery of 115 images | Williams claimed counsel’s failure deprived him of exculpatory material and arguable issues for trial | Commonwealth/PCRA court: Williams did not establish the Pierce prongs (merit, lack of reasonable basis, prejudice) | Held claim fails for inadequate pleading/proof and lack of arguable merit/prejudice |
| Whether counsel ineffectively cross‑examined multiple eyewitnesses and a detective | Williams said counsel failed to expose inconsistencies and impeach witnesses (O’Neal, King, Carter, Jones, Roger King, Detective Cahill) | Commonwealth: appellate record does not support that deficient performance resulted in prejudice; petitioner did not explain counsel’s lack of reasonable basis | Held claim fails for failure to plead the Pierce factors and for lack of prejudice/arguable merit |
| Whether counsel should have moved to suppress an out‑of‑court identification and pursued alternate‑shooter (Jamal Simmons) theory | Williams alleged identification reliability and alternate shooter evidence would have affected outcome | Commonwealth: record lacks support for meritorious suppression or showing of prejudice; claims not adequately developed | Held claim fails; no hearing required because claims lack arguable merit or prejudice |
Key Cases Cited
- Commonwealth v. Jones, 942 A.2d 903 (Pa. Super. 2008) (no absolute right to PCRA evidentiary hearing when record shows no genuine issue of material fact)
- Commonwealth v. Barbosa, 819 A.2d 81 (Pa. Super. 2003) (PCRA hearing principles and inquiry into factual disputes)
- Commonwealth v. Reyes‑Rodriguez, 111 A.3d 775 (Pa. Super. 2015) (describing Pierce three‑part test for counsel ineffectiveness and when hearings are required)
- Commonwealth v. Pierce, 527 A.2d 973 (Pa. 1987) (establishing the three‑prong test for ineffective assistance of counsel)