Com. v. Williams, R.
275 EDA 2017
Pa. Super. Ct.Dec 5, 2017Background
- In November 2008 parole agents found Ronald Williams with large quantities of narcotics, multiple firearms, and mistreated pit bulls tied to illegal dog fighting.
- Williams pleaded guilty in February 2011 to possession with intent to deliver, a firearms offense, and animal fighting; he received an aggregate 6–12 year sentence and filed no direct appeal or post-sentence motions.
- Williams filed a first PCRA petition in 2011, which was denied after an evidentiary hearing and affirmed on appeal.
- On March 19, 2015 Williams filed a second (pro se) PCRA petition alleging the Commonwealth withheld impeachment evidence concerning former Officer Michael Spicer, who allegedly had been investigated for corruption from 2006–2012.
- The PCRA court issued Pa.R.Crim.P. 907 notice and dismissed the petition on January 6, 2017 as untimely and failing to satisfy a statutory timeliness exception; Williams appealed.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (Commonwealth) | Held |
|---|---|---|---|
| Whether the PCRA court erred by dismissing without an evidentiary hearing | Williams: new impeachment evidence about Officer Spicer excused untimeliness and warranted a hearing | Commonwealth: petition is patently untimely and fails to prove a §9545(b)(1) exception, so no hearing is required | Court: No error — dismissal without a hearing was proper because no timeliness exception was proven |
| Whether newly discovered evidence or governmental interference made petition timely | Williams: private investigator discovered the Commonwealth’s witness list showing Spicer was to testify and had been investigated; this is newly discovered/governmental suppression | Commonwealth: Williams failed to explain due diligence delay and did not show active suppression or newly discoverable facts within 60 days | Court: Williams failed to meet the 60-day filing requirement for §9545(b)(1) exceptions; claim untimely |
| Whether nondisclosure of impeachment material vitiates a guilty plea | Williams: he would not have pleaded guilty if he had Spicer impeachment material | Commonwealth: prosecution is not required to disclose impeachment material before a plea (Ruiz) | Court: Ruiz controls; impeachment evidence does not automatically invalidate a plea and does not excuse untimeliness |
| Whether after-discovered-evidence claim would entitle relief | Williams: impeachment evidence would have changed outcome at trial | Commonwealth: impeachment-only evidence does not satisfy PCRA’s after-discovered-evidence standard | Court: Even if timely, impeachment-only evidence would not meet §9543(a)(2) because it would be used solely to impeach and likely would not change the result |
Key Cases Cited
- Johnston v. Commonwealth, 42 A.3d 1120 (Pa. Super. 2012) (standard of review for PCRA denials)
- Gamboa-Taylor v. Commonwealth, 753 A.2d 780 (Pa. 2000) (PCRA timeliness exceptions and 60-day rule)
- Alcorn v. Commonwealth, 703 A.2d 1054 (Pa. Super. 1997) (PCRA filing deadlines for second or subsequent petitions)
- Robinson v. Commonwealth, 837 A.2d 1157 (Pa. 2003) (PCRA timeliness is jurisdictional)
- United States v. Ruiz, 536 U.S. 622 (2002) (prosecution not required to disclose impeachment evidence before a plea)
- Commonwealth v. Burton, 158 A.3d 618 (Pa. 2017) (after-discovered-evidence claim cannot rest solely on impeachment evidence)