Com. v. Williams, M., 2836 EDA 2015

Background

Police conducted a trash pull outside 1415 Pine Street and recovered items (batteries, starter fluid, ammonia test kits, sliced cold packs, pseudoephedrine blister packs, a melted bottle with white solid, mail addressed to Michael Williams) that the Clandestine Response Team concluded were components/chemicals for methamphetamine production.
A magistrate issued a search warrant for 1415 Pine Street; execution recovered additional items (cut cold compresses, starting fluid, baking soda, salt, ammonia nitrate test kit, isopropyl alcohol, respirator, meth pipes).
Rebecca Patrick, a PSP lab technician, testified as an expert: trash-pull liquid tested positive for methamphetamine crystals; other seized items were consistent with the one‑pot meth method; blister packs contained pseudoephedrine.
Williams gave a recorded statement and wrote letters discussing meth production; jury convicted him of operating a meth lab and related offenses and found he manufactured between 5 and 10 grams; he was sentenced to 6.25–21 years, resentenced after Alleyne challenge.
Williams filed a timely pro se PCRA petition alleging trial counsel was ineffective for (1) not filing a suppression motion challenging the warrant, (2) not challenging scientific evidence or retaining an expert, (3) not objecting to prosecutor closing remarks, and (4) not calling Dawn Stocker as a witness. The PCRA court denied relief; Superior Court affirmed.

Issues

Issue	Williams' Argument	Commonwealth / Trial Counsel Argument	Held
Failure to file suppression motion	Counsel should have moved to suppress search results because warrant was invalid/unsigned or officers entered without paperwork	Warrant was properly reviewed and signed by the magisterial judge; counsel did receive and review the warrant and had reasonable basis not to file a meritless motion	No ineffectiveness: suppression claim lacked arguable merit; counsel had reasonable basis not to file motion
Failure to challenge scientific evidence / not retaining expert	Counsel should have hired an expert or demanded additional discovery to attack lab testing and methodology	PSP expert had practical qualifications; lab reports and testimony were not facially defective; counsel cross‑examined the expert and saw no red flags	No ineffectiveness: evidence/admission of expert testimony was proper; counsel’s tactical choice reasonable
Failure to object to prosecutor closing remarks	Prosecutor misstated ingredients and implied presence of red phosphorus and improper inferences requiring objection	Remarks were argument based on evidence and reasonable inferences from testimony and exhibits; closing is afforded wide latitude	No ineffectiveness: comments were permissible or not prejudicial; omission of objection not reversible error
Failure to call Dawn Stocker	Stocker would have testified she rented another apartment and the police were targeting others, undermining search legitimacy	Counsel interviewed Stocker and declined to call her due to credibility/prior record concerns; her testimony would have been irrelevant to trash‑pull and subsequent warrant execution	No ineffectiveness: proposed testimony was not sufficiently relevant or likely to change outcome; counsel’s decision had reasonable basis

Key Cases Cited

Alleyne v. United States, 133 S. Ct. 2151 (2013) (mandatory‑minimum sentencing issue requiring resentencing)
Commonwealth v. Mason, 130 A.3d 601 (Pa. 2015) (standard for ineffective assistance under Strickland/Pierce)
Commonwealth v. Pierce, 537 Pa. 514, 645 A.2d 189 (1994) (threshold of arguable merit and reasonable basis analysis for counsel decisions)
Commonwealth v. Spotz, 18 A.3d 244 (Pa. 2011) (PCRA standard of review; expert testimony admissibility principles)
Commonwealth v. Chambers, 807 A.2d 872 (Pa. 2002) (prejudice standard for ineffective assistance claims)
Commonwealth v. Gerald Mason, 490 A.2d 421 (Pa. 1985) (exclusionary rule and when procedural violations require suppression)