Com. v. Williams, V.
Com. v. Williams v. No. 844 WDA 2016
| Pa. Super. Ct. | Apr 20, 2017Background
- Vernon Williams was convicted by a jury of first-degree murder and conspiracy on November 20, 2003, and sentenced to life imprisonment. He was 19 at the time of the offense.
- The Pennsylvania Supreme Court denied allowance of appeal on December 7, 2005.
- Williams filed a pro se third PCRA petition on March 10, 2016, while an appeal of his second, untimely PCRA petition was still pending.
- The PCRA court dismissed the third petition as time‑barred and for lack of jurisdiction because the court had no authority to address a successive petition while an appeal from a prior PCRA denial was pending.
- Williams based his claim on Miller and Montgomery, asserting Miller’s rule (that mandatory life‑without‑parole for juveniles is unconstitutional) should apply, but he conceded he was 19 at the time of the crime.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the PCRA court had jurisdiction to hear Williams’s third PCRA petition filed while an appeal from denial of his second PCRA petition was pending | Williams filed the third petition and asked for relief under Miller/Montgomery | Commonwealth argued the court lacked jurisdiction and the petition was time‑barred | Court held it lacked jurisdiction and dismissed the petition (time‑barred) |
| Whether Miller/Montgomery entitle Williams to relief | Miller/Montgomery announce a new substantive rule that should apply retroactively | Commonwealth noted Miller applies only to defendants under 18 at the time of the offense; Williams was 19 | Court held Miller does not apply to Williams because he was 19 when the crime occurred; no relief due |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life-without-parole for juveniles violates the Eighth Amendment)
- Montgomery v. Louisiana, 577 U.S. 190 (2016) (Miller announced a new substantive rule that applies retroactively)
- Commonwealth v. Lark, 746 A.2d 585 (Pa. 2000) (PCRA court lacks jurisdiction to entertain successive petitions while appeal pending)
- Commonwealth v. Jones, 700 A.2d 423 (Pa. 1997) (prisoner mailbox rule for timely filing by incarcerated appellants)