Com. v. Williams, R.
1812 WDA 2016
| Pa. Super. Ct. | Oct 12, 2017Background
- In 1998 Ronald Williams participated in a group shooting that killed Jason Faulk; Williams was convicted of first‑degree murder and related offenses and sentenced to mandatory life without parole plus consecutive terms.
- Direct appeal and state postconviction proceedings occurred; Williams’s judgment became final on February 17, 2009 after the Pennsylvania Supreme Court denied allowance of appeal nunc pro tunc.
- Williams filed multiple PCRA petitions; the 2016 filing was his third PCRA petition and was facially untimely (filed April 5, 2016).
- Williams alleged newly discovered evidence in 2016: an inmate (Pinson) provided him documents and an affidavit suggesting Detectives Logan and McDonald had a history of coercive interrogation and fabrication (materials stemming from Manns civil litigation and OMI reports from 1999–2002).
- He invoked the §9545(b)(1)(ii) "newly discovered facts" exception, claiming he could not have discovered those public records earlier due to being a pro se prisoner.
- The PCRA court dismissed the petition as untimely under the PCRA; the Superior Court affirmed, holding Williams failed to plead or prove due diligence and thus the court lacked jurisdiction to consider the merits.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (Commonwealth/PCRA court) | Held |
|---|---|---|---|
| Timeliness under 42 Pa.C.S. § 9545(b)(1)(ii) ("newly discovered facts") | Pinson revealed evidence in Feb 2016 showing detectives fabricated/confessed pattern of misconduct; materials were not known to Williams earlier because he is a pro se inmate | The OMI reports and Manns litigation were public record (1999–2002); Williams and prior counsel could have discovered them earlier; Williams failed to plead due diligence or explain delay | Petition untimely; Williams failed to establish the newly discovered facts exception because he did not plead or prove due diligence; dismissal affirmed |
| Brady/due process claim re: detective misconduct | Prosecutor violated Brady by relying on or failing to disclose misconduct records of Detectives Logan and McDonald | Court lacked jurisdiction to reach Brady claim because petition is untimely and no exception was proved | Not reached on merits; claim rejected for lack of jurisdiction due to untimeliness |
Key Cases Cited
- Commonwealth v. Bennett, 930 A.2d 1264 (Pa. 2007) (explains two components of §9545(b)(1)(ii): facts were unknown and could not have been discovered with due diligence)
- Commonwealth v. Stokes, 959 A.2d 306 (Pa. 2008) (60‑day filing requirement for statutory exceptions requires pleading and proof that information could not have been obtained earlier despite due diligence)
- Commonwealth v. Breakiron, 781 A.2d 94 (Pa. 2001) (interpreting newly discovered facts exception and timeliness requirements)
- Commonwealth v. Monaco, 996 A.2d 1076 (Pa. Super. 2010) (due diligence requires reasonable steps to protect one's own interests; requirement is strictly enforced)
- Commonwealth v. Burton, 158 A.3d 618 (Pa. 2017) (addresses treatment of public‑record evidence for pro se prisoner petitioners but confirms due diligence requirement remains)
- Commonwealth v. Taylor, 67 A.3d 1245 (Pa. 2013) (public‑record materials are generally not "unknown" for §9545(b)(1)(ii) purposes)
- Commonwealth v. Jackson, 30 A.3d 516 (Pa. Super. 2011) (courts lack jurisdiction to grant relief when statutory timeliness exceptions are not established)
- Commonwealth v. Eichinger, 108 A.3d 821 (Pa. 2014) (standard of review for PCRA denials)