Com. v. Williams, T.
220 A.3d 1086
Pa. Super. Ct.2019Background
- January 5, 2012: Stewart and Baird met at a bar and went to Baird’s house to buy marijuana; the buy turned out to be the wrong drug and Baird called the seller back.
- The seller returned with three men, including Williams; a group assault occurred in the kitchen: Stewart was struck, hit with a bottle, kicked, stomped, and had hot oil poured on him; his wallet and cell phone were taken.
- Williams was tried by jury, convicted of two counts of robbery (one for putting in fear of serious bodily injury, one for inflicting bodily injury), theft by unlawful taking, and simple assault, and sentenced to 6–12 years plus supervision.
- On PCRA review Williams raised ineffective-assistance claims: failure to move to suppress pre-Miranda statements, failure to seek a new jury pool after Juror #29’s comment, failure to impeach witness Baird about work-release (bias), and failure to challenge sufficiency of certain convictions on direct appeal.
- The PCRA court dismissed Williams’ petition; the Superior Court considered waiver of some claims, reviewed preserved issues under the three-part ineffectiveness test, and affirmed the dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to move to suppress pre-Miranda statements | Williams: police questioned him in custody before Miranda warnings; counsel ineffective for not moving to suppress those statements | Commonwealth: agent eventually Mirandized and elicited admissions; other properly admitted evidence proved guilt | Court: Miranda protections applied; suppression error for pre-warning statements but error was harmless given other inculpatory evidence and post-warning admissions — no relief |
| Failure to obtain new jury pool after Juror #29 comment | Williams: Juror #29 told panel she heard about his case via a prison guard (fiancé); counsel ineffective for not moving for new jury pool | Commonwealth: judge questioned and excused Juror #29; brief exposure did not prejudice panel | Court: no merit; juror was excused and comment not so prejudicial as to require new pool |
| Failure to impeach witness Baird about work-release (bias) | Williams: counsel failed to elicit that Baird was on work-release/probation and thus biased for the prosecution | Commonwealth: Baird’s testimony was not more damaging than Williams’ own admissions; any bias would be unlikely to change outcome | Court: work-release is a non-final disposition and should have been explored, but omission was harmless given Williams’ admissions and other testimony — no relief |
| Failure to challenge sufficiency of evidence on remaining convictions | Williams: appellate counsel omitted sufficiency challenges to robbery (inflicts bodily injury), theft, and simple assault | Commonwealth: trial record contained victim testimony and Williams’ admissions supporting those convictions | Court: conviction evidence sufficient; Williams admitted assault and jury could infer theft and robbery participation — claim fails |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires warnings before admissible statements)
- Commonwealth v. Ali, 10 A.3d 282 (Pa. 2010) (three-part ineffective-assistance test)
- Commonwealth v. Gaul, 912 A.2d 252 (Pa. 2006) (Miranda necessity and totality analysis)
- Commonwealth v. DeJesus, 787 A.2d 394 (Pa. 2001) (definition of interrogation and functional equivalent)
- Commonwealth v. Tedford, 960 A.2d 1 (Pa. 2008) (voir dire exposure to outside information does not automatically disqualify jurors)
- Commonwealth v. Baez, 21 A.3d 1280 (Pa. 1998) (Commonwealth bears burden to prove valid Miranda waiver)
- Commonwealth v. Fay, 344 A.2d 473 (Pa. 1975) (failure to suppress statements may be harmless error)
- Commonwealth v. Buksa, 655 A.2d 576 (Pa. Super. 1995) (probation as non-final disposition relevant to impeachment bias)
- Commonwealth v. Melius, 100 A.3d 682 (Pa. Super. 2014) (county intermediate punishment/work-release analogous to probation for revocation and bias purposes)