Com. v. Williams, W.
Com. v. Williams, W. No. 567 EDA 2016
| Pa. Super. Ct. | Mar 13, 2017Background
- On February 11, 2000, police pursuing a stolen Mercedes observed a vehicle matching the description; the driver (William C. Williams) fled, crashed into a Plymouth Neon, killing its driver and seriously injuring a passenger.
- Williams was convicted after a jury trial (April 17, 2001) of multiple offenses including third-degree murder, homicide by vehicle, aggravated assault, receiving stolen property, causing an accident while not properly licensed, and fleeing/eluding. He received an aggregate sentence of 22 to 44 years.
- Direct appeal and subsequent collateral challenges: Superior Court affirmed (2003); PA Supreme Court denied allowance (2005). Williams filed multiple PCRA petitions: first in 2005 (denied), second in 2011 (denied), and the instant, third PCRA petition filed March 2, 2015.
- The PCRA court dismissed the third petition as untimely under 42 Pa.C.S. § 9545(b)(1); the court found Williams failed to prove any of the statutory exceptions to the one-year filing requirement.
- Williams argued the petition was timely under the exceptions because his sentence was illegal, trial counsel was ineffective (Confrontation Clause violations), and Montgomery/Miller decisions applied; the PCRA court and Superior Court rejected these arguments.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (Commonwealth / PCRA court) | Held |
|---|---|---|---|
| Timeliness of PCRA petition | Petition timely via exceptions: sentence illegal; counsel ineffective; Montgomery/Miller apply | Petition was filed March 2, 2015, well beyond the one-year deadline (final May 25, 2005); no timely pleading of any §9545(b) exception | Petition untimely; court lacked jurisdiction to reach merits |
| Legality of sentence (including credit/time and fleeing sentence) | Sentence illegal and merits entitle him to resentencing/credit and relief from an excessive fleeing sentence | Legality claims are subject to PCRA time limits; Williams did not satisfy any timeliness exception | Not addressed on merits — untimely claim; no relief |
| Ineffective assistance / Confrontation Clause (admission of medical records, hearsay establishing serious bodily injury) | Trial counsel ineffective for failing to object to medical records and hearsay; Confrontation Clause violated, warranting new trial | Ineffective-assistance claims do not excuse untimeliness; Williams failed to plead or prove a timely exception | Claim rejected on timeliness grounds; merits not reached |
Key Cases Cited
- Commonwealth v. Robinson, 139 A.3d 178 (Pa. 2016) (standard of review for PCRA denials)
- Commonwealth v. Callahan, 101 A.3d 118 (Pa. Super. 2014) (timeliness of PCRA petitions reviewed de novo)
- Commonwealth v. Edmiston, 65 A.3d 339 (Pa. 2013) (petitioner must carry burden of pleading timeliness exception before merits)
- Commonwealth v. Jackson, 30 A.3d 516 (Pa. Super. 2011) (legality-of-sentence claims are cognizable under the PCRA but must be timely)
- Commonwealth v. Fahy, 737 A.2d 214 (Pa. 1999) (legality claims subject to PCRA time limits)
- Commonwealth v. Wharton, 886 A.2d 1120 (Pa. 2005) (ineffective-assistance allegations do not excuse untimely PCRA petitions)
- Commonwealth v. Lark, 746 A.2d 585 (Pa. 2000) (same principle regarding ineffectiveness and timeliness)
- Commonwealth v. Wyatt, 115 A.3d 876 (Pa. Super. 2015) (time-credit claims implicate legality of sentence and are subject to PCRA timeliness)
- Commonwealth v. Bennett, 930 A.2d 1264 (Pa. 2007) (jurisdictional nature of PCRA time limits)
- Commonwealth v. Fairiror, 809 A.2d 396 (Pa. Super. 2002) (PCRA court lacks jurisdiction to hear untimely petition)