Com. v. Williams, E.
820 EDA 2017
| Pa. Super. Ct. | Dec 20, 2017Background
- Eric Williams was convicted of second-degree murder in 1990 and sentenced to life; direct appeals were exhausted in 1996.
- Williams filed his fourth PCRA petition on May 10, 2016, more than 19 years after his judgment became final.
- He relied on a March 26, 2016 letter from Commonwealth witness Harold Jackson recanting trial testimony.
- Williams had alleged awareness of Jackson’s recantation as early as 1994 in an affidavit he submitted to the PCRA court.
- The PCRA court dismissed the petition as untimely under 42 Pa.C.S. § 9545(b) because no applicable timeliness exception was shown.
- The Superior Court affirmed, holding Jackson’s letter did not present a newly discovered “fact” for purposes of the PCRA time‑bar.
Issues
| Issue | Williams' Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Whether Williams’ petition was timely under the PCRA’s newly‑discovered‑fact exception (§ 9545(b)(1)(ii)) | The Jackson letter is a newly discovered recantation that tolled timeliness and the petition was filed within 60 days of discovery | The recantation was not a new fact; Williams knew of Jackson’s recantation in 1994, so the exception does not apply | Court held the letter was merely a new source for old facts; exception not satisfied and petition untimely |
| Whether the PCRA court had jurisdiction to hear the petition | N/A (relying on the exception) | Because the petition was untimely and no exception applied, the court lacked jurisdiction | Court affirmed lack of jurisdiction due to failure to plead a timely exception |
Key Cases Cited
- Commonwealth v. Medina, 92 A.3d 1210 (Pa. Super. 2014) (standard of review for PCRA appeals and scope of record)
- Commonwealth v. Bretz, 830 A.2d 1273 (Pa. Super. 2003) (PCRA one‑year filing requirement explained)
- Commonwealth v. Pollard, 911 A.2d 1005 (Pa. Super. 2006) (judgment finality and PCRA timeliness)
- Commonwealth v. Ali, 86 A.3d 173 (Pa. 2014) (PCRA time limits are jurisdictional; equitable tolling unavailable)
- Commonwealth v. Bennett, 930 A.2d 1264 (Pa. 2007) (newly discovered facts exception requires facts unknown to petitioner)
- Commonwealth v. Johnson, 863 A.2d 423 (Pa. 2004) (distinguishing newly discovered facts from a new source for known facts)
- Commonwealth v. Abu–Jamal, 941 A.2d 1263 (Pa. 2008) (additional witness or affidavit does not convert known facts into newly discovered facts)
- Commonwealth v. Marshall, 947 A.2d 714 (Pa. 2008) (applying Johnson and Abu–Jamal to reject recantation as a newly discovered fact)