Commonwealth, Aplt v. Williams, T.
105 A.3d 1234
| Pa. | 2014Background
- Appellee (Williams) was convicted of murder (Norwood) and sentenced to death; conviction affirmed on direct appeal and prior collateral review, with multiple earlier PCRA petitions and federal habeas denied.
- In 2012 the Federal Community Defenders Office (FCDO) obtained new affidavits from co-defendant Marc Draper asserting Norwood was homosexual and had a sexual relationship with Williams; Draper said prosecutors had emphasized robbery as the motive at trial.
- Williams filed a fourth, facially untimely PCRA petition alleging Brady violations based on withheld or “sanitized” materials (wife’s statement, pastor’s statement, prosecutor’s handwritten notes) that purportedly showed Norwood’s homosexual ephebophilia and thus would have affected the penalty phase.
- The PCRA court ordered production of Commonwealth and police files, held an evidentiary hearing, found Brady and governmental-interference exceptions met, stayed execution, and granted a new penalty hearing.
- The Commonwealth appealed; the Pennsylvania Supreme Court reviewed timeliness (jurisdiction) and Brady materiality and ultimately vacated the stay and reinstated the death sentence.
Issues
| Issue | Williams' Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Timeliness — whether fourth PCRA petition fits §9545(b)(1) exceptions | Fourth petition timely under governmental-interference exception because prosecution’s nondisclosure (and Draper’s affidavits) prevented earlier presentation; Williams filed within 60 days of learning facts | Petition untimely: Williams knew or could have discovered the victim’s sexual conduct long before; Draper’s info derived from Williams; no governmental interference | Held: Petition did not meet governmental-interference exception; untimely and jurisdictionally barred |
| Brady — whether nondisclosed materials were exculpatory and material to penalty phase | Withheld files would have allowed defense to depict Norwood as a sexual predator and changed penalty outcome; evidence discovered only after Draper’s affidavit | Materials were cumulative or already known to Williams; not exculpatory or material to change verdict/penalty; Brady not meant to shield defendant from his own perjury | Held: No Brady violation; withheld items not material or newly-discovered in a way that undermines confidence in outcome |
| Scope of PCRA court discovery/evidentiary powers in serial capital petitions | (Implicit) Court empowered to order discovery/hearings to evaluate claims after new affidavits | PCRA court exceeded its jurisdiction and procedural limits by seizing files, conducting sua sponte review, and holding hearings before timeliness established | Held: PCRA court erred procedurally; cannot retroactively validate sua sponte discovery when jurisdiction lacking |
| Effect of defendant’s trial perjury on Brady and timeliness analysis | Additional disclosures could have altered Williams’ decision to testify and strategy, affecting outcome | A defendant’s perjury does not convert non-disclosure into Brady materiality; prior knowledge vitiates interference claim | Held: Defendant’s known facts and chosen perjured defense foreclose Brady relief and timeliness exception |
Key Cases Cited
- Commonwealth v. Williams, 524 Pa. 218 (Pa. 1990) (direct-appeal disposition of Norwood conviction)
- Commonwealth v. Williams, 581 Pa. 57 (Pa. 2004) (prior PCRA appeal addressing related claims)
- Williams v. Beard, 637 F.3d 195 (3d Cir. 2011) (federal habeas disposition summarizing prior record about sexual relationship and abuse)
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution duty to disclose exculpatory evidence)
- Commonwealth v. Abu-Jamal, 596 Pa. 219 (Pa. 2008) (explaining governmental-interference exception to PCRA timeliness)
- Commonwealth v. Weiss, 622 Pa. 663 (Pa. 2013) (discussion on limits of Brady materiality and effect-on-defense theories)