Commonwealth, Aplt. v. Williams, C.
141 A.3d 440
| Pa. | 2016Background
- Christopher Williams was convicted in 1993 of three first‑degree murders based principally on testimony from James White, a jailhouse informant/accomplice; Williams received three consecutive death sentences.
- White testified the victims were shot inside a van and two were thrown from the moving vehicle; forensic evidence at trial showed no non‑gunshot abrasions or clothing damage and blood patterns at the scenes.
- Trial counsel did not question the Commonwealth’s medical examiners on whether the physical evidence contradicted White’s account and did not retain a defense forensic/medical expert.
- On collateral review (PCRA), Williams proffered two experts (Dr. Charles Wetli, forensic pathologist, and Robert Tressel, crime‑scene/blood‑flow analyst) who testified the blood‑flow, location of bodies, and absence of abrasions were inconsistent with being shot in a van and thrown from it.
- The PCRA court credited the defense experts, found trial counsel ineffective for failing to investigate/call experts or meaningfully cross‑examine the Commonwealth’s experts, and granted a new trial; the Commonwealth appealed.
- The Pennsylvania Supreme Court affirmed in part — holding appellate counsel ineffective for failing to raise trial counsel’s ineffectiveness on direct appeal and affirming the grant of a new trial on that basis.
Issues
| Issue | Plaintiff's Argument (Commonwealth or Williams) | Defendant's Argument (other party) | Held |
|---|---|---|---|
| Whether the PCRA court erred by allowing Tressel’s blood‑flow testimony added post‑remand | Commonwealth: amendment raised a new, untimely claim beyond scope of remand | Williams: testimony merely substituted new experts for deceased originally proffered expert; falls within original claim | Court: Allowed testimony — substitution of experts for originally alleged forensic claim was permissible |
| Whether trial counsel was ineffective for failing to retain/call forensic experts and for not cross‑examining Commonwealth experts on blood patterns and abrasions | Commonwealth: counsel’s strategy to rely on co‑defendants’ cross‑examination and common‑sense argument was reasonable; hindsight review improper; evidence was not clearly exculpatory | Williams: expert testimony would have contradicted White on critical points and counsel made no investigation or strategic decision to omit experts | Court: Trial counsel ineffective regarding Tressel’s blood‑flow/gunshot‑wound issues; prejudice shown — new trial warranted on that basis |
| Whether Dr. Wetli’s post‑conviction testimony provided arguable merit to the ineffectiveness claim | Commonwealth: Wetli’s opinions were speculative and would have added little; possibly inadmissible as lay‑accessible observations | Williams: Wetli’s pathology opinion supported that bodies were not expelled from a van and trial counsel should have used such testimony | Court: Majority found Wetli’s testimony of limited benefit and rejected that portion as arguable merit; concurrence disagreed and would credit Wetli |
| Whether appellate counsel was ineffective for not raising the trial‑counsel ineffectiveness claim on direct appeal | Commonwealth: appellate counsel reasonably winnowed issues and pursued record‑based appellate strategy; no unreasonable omission | Williams: appellate counsel failed to investigate non‑record issues and omitted a meritorious claim without reasonable basis | Court: Appellate counsel ineffective for failing to raise the trial‑counsel expert‑omission claim; reasonable probability outcome of direct appeal would differ; supports new trial |
Key Cases Cited
- Commonwealth v. Williams, 720 A.2d 679 (Pa. 1998) (Williams I) (prior direct‑appeal decision reviewing multiple issues)
- Commonwealth v. Williams, 936 A.2d 12 (Pa. 2007) (Williams II) (remand and McGill guidance on layered ineffectiveness)
- Commonwealth v. Besch, 674 A.2d 655 (Pa. 1996) (construction of corrupt organizations statute relevant to prejudice from vacated conviction)
- Commonwealth v. McGill, 832 A.2d 1014 (Pa. 2003) (procedural framework for pleading layered ineffective‑assistance claims)
- Commonwealth v. Chmiel, 30 A.3d 1111 (Pa. 2011) (standards for trial counsel’s duty to call experts and prejudice analysis)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑prong standard — performance and prejudice — governing ineffective assistance claims)