Com. v. Williams, R.
Com. v. Williams, R. No. 584 MDA 2016
| Pa. Super. Ct. | Aug 8, 2017Background
- Robert C. Williams was tried for the November 10, 2011 robbery and murder of Stanley Cotton (and a related robbery of Bobby Barnes); a jury convicted him of second-degree murder and two counts of robbery and he received mandatory life imprisonment.
- Williams did not file a direct appeal initially; his PCRA petition later reinstated appellate rights and this Court affirmed his judgment on direct appeal in 2015.
- Williams filed a pro se PCRA petition in June 2015; counsel was appointed and filed an amended petition. The PCRA court held an evidentiary hearing and denied relief on March 11, 2016.
- Williams argued trial counsel was ineffective for three reasons: (1) failing to obtain medical records and move to suppress a hospital interview while medicated; (2) inadequately discussing and thereby preventing Williams from exercising his right to testify; (3) failing to redact/object to testimony that Williams had previously been shot and to seek a mistrial.
- The PCRA court credited trial counsel’s strategic explanations: counsel wanted the jury to hear Williams’ exculpatory hospital statements, trial counsel did not interfere with the defendant’s decision not to testify and the trial court’s colloquy confirmed that decision, and counsel intentionally avoided objecting to fleeting references to a prior shooting to avoid highlighting them.
- The PCRA court found Williams failed to establish arguable merit, lack of reasonable basis, and prejudice for each ineffective-assistance claim; this Superior Court affirmed the denial of PCRA relief.
Issues
| Issue | Williams' Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| 1) Whether counsel was ineffective for not obtaining medical records and moving to suppress Williams’ hospital interview while medicated | Counsel should have investigated medication effects and sought suppression because the interview occurred while Williams had received oxycodone and gabapentin | Counsel had a reasonable strategic basis to let the recorded, consistent, exculpatory statements be presented to the jury; no evidence medication impaired understanding; suppression would not have changed outcome | Denied — counsel’s strategy was reasonable and Williams showed no prejudice |
| 2) Whether counsel was ineffective for failing to adequately discuss or allow Williams to testify | Counsel failed to adequately advise Williams and effectively prevented him from exercising his right to testify | Trial court conducted a thorough colloquy; Williams knowingly and intelligently waived testifying; no evidence counsel interfered or gave unreasonable advice | Denied — waiver was knowing; no interference or prejudice shown |
| 3) Whether counsel was ineffective for not objecting/redacting testimony that Williams had been shot or seeking a mistrial | Counsel should have objected or sought a mistrial because references to a prior shooting were highly prejudicial | Counsel reasonably declined to object to avoid highlighting fleeting, non-detailed references; evidence of drug involvement already introduced; no prejudice shown | Denied — trial strategy reasonable and no reasonable probability of different outcome |
Key Cases Cited
- Commonwealth v. Pierce, 786 A.2d 203 (Pa. 2001) (sets three-prong ineffective-assistance-of-counsel test)
- Commonwealth v. Poplawski, 130 A.3d 697 (Pa. 2015) (statement suppression turns on whether statement was product of free and unconstrained choice)
- Commonwealth v. Jones, 942 A.2d 903 (Pa. Super. 2008) (ineffective-assistance claim based on failure to pursue suppression requires proof of underlying suppression claim merit)
- Commonwealth v. Freeland, 106 A.3d 768 (Pa. Super. 2014) (trial counsel not required to lodge all possible objections; objections may highlight issues for jury)