Com. v. Williams, E., Com. v. Williams, E. No. 3184 EDA 2016

Appellant Eleanor Monique Williams pleaded guilty (Oct. 15, 2015) to failure to control or report dangerous fires after starting a fire that destroyed a residence.
The trial court sentenced Williams to 86 days to 24 months less one day, followed by three years’ probation, credited her with 86 days, and released her on immediate parole.
On March 3, 2016, Williams was found to have violated parole/probation for possessing two knives; the court remanded her to county jail for the balance of her term with re-parole possible after a minimum of one month, and credited 15 days’ time served.
The court entered an order (Mar. 23, 2016) releasing Williams on parole subject to verification of a suitable home plan; Williams was unable to obtain a suitable plan and remained incarcerated.
Williams filed a counseled petition for a writ of habeas corpus (Jul. 26, 2016) seeking immediate release for unlawful detention; the trial court denied the petition (Sept. 14, 2016), Williams appealed, but was released on re-parole while the appeal was pending (Oct. 21, 2016).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in denying Williams's petition for a writ of habeas corpus and ordering her continued detention for lack of a suitable home plan	Williams argued her continued incarceration was unlawful because she could not obtain a probation-approved home plan and received no assistance	The Commonwealth/trial court (as acknowledged by counsel) argued the claim is moot because Williams was released from incarceration while the appeal was pending	Appeal dismissed as moot; no meaningful relief available because Williams was released; counsel's petition to withdraw denied without prejudice

Anders v. California, 386 U.S. 738 (U.S. 1967) (procedural framework for appointed counsel to seek withdrawal on direct appeal)
Santiago v. Commonwealth, 978 A.2d 349 (Pa. 2009) (discussing counsel’s obligations on appeal and Anders procedure)
Joseph v. Glunt, 96 A.3d 365 (Pa. Super. 2014) (defines habeas corpus relief as immediate release from unlawful detention; standard of review is abuse of discretion)
Commonwealth v. Sloan, 907 A.2d 460 (Pa. 2006) (recognizes doctrine of mootness and dismissal when no practical relief can be granted)
Commonwealth v. Nava, 966 A.2d 630 (Pa. Super. 2009) (defines mootness as when a determination cannot have a practical effect on the existing controversy)