Com. v. Wilson, A.
663 EDA 2016
| Pa. Super. Ct. | Dec 7, 2016Background
- In 1994 Aaron Wilson pled guilty to multiple state charges (robbery, conspiracy, firearms offenses, aggravated assault, and possession with intent to deliver) pursuant to a plea agreement and received an aggregate sentence of 5–10 years.
- Wilson filed a "Petition for Common Law Writ of Error Coram Nobis" on June 9, 2015, challenging the validity of his 1994 guilty plea and alleging ineffective assistance of plea counsel and lack of jurisdiction for several charges.
- Wilson conceded his state sentence expired March 17, 2004, and explained his motive: the state convictions operated as predicates for later federal firearms convictions.
- The trial court treated the petition as a Post Conviction Relief Act (PCRA) petition and dismissed it because Wilson was no longer serving a sentence on the challenged convictions, making him ineligible for PCRA relief.
- On appeal, Wilson argued the PCRA did not bar his coram nobis petition; the Superior Court considered whether his claims were subsumed by the PCRA and whether the appeal was timely (prisoner mailbox rule applied).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether PCRA is the exclusive remedy for claims challenging the validity of a criminal conviction/sentence (i.e., whether coram nobis is available) | Wilson argued his coram nobis petition should be considered outside the PCRA and that coram nobis relief could address collateral consequences used against him federally | Commonwealth argued the PCRA subsumes coram nobis and other collateral remedies when the claims attack a conviction or sentence that could be remedied under the PCRA | The court held the PCRA is the exclusive remedy for these claims; Wilson’s challenges attack the judgment of sentence and are therefore encompassed by the PCRA, barring coram nobis relief |
| Whether Wilson’s appeal was timely given filing delays while incarcerated (application of prisoner mailbox rule) | Wilson relied on the prisoner mailbox rule to establish timeliness because he was incarcerated and dated his filing earlier | Commonwealth did not successfully contest the application of the mailbox rule on appeal | The court applied the prisoner mailbox rule and concluded the appeal was timely |
Key Cases Cited
- Commonwealth v. Pagan, 864 A.2d 1231 (Pa. Super. 2004) (PCRA subsumes coram nobis when the claim could be remedied under the PCRA)
- Commonwealth v. West, 938 A.2d 1034 (Pa. 2007) (PCRA subsumes all collateral relief to the extent remedies are available under the statute)
- Commonwealth v. Eller, 807 A.2d 838 (Pa. 2002) (claims that could be remedied under the PCRA are exclusive to the PCRA)
- Commonwealth v. Chester, 733 A.2d 1242 (Pa. 1999) (other collateral procedures are available only where the PCRA does not encompass the claim)