Commonwealth, Aplt v. Williams, T., Commonwealth, Aplt v. Williams, T.

Background

In 1984 Terrance Williams and Marc Draper abducted and murdered Amos Norwood; Williams was convicted of first-degree murder and sentenced to death in 1986. Williams’ direct appeal and initial collateral review were unsuccessful.
Williams filed multiple PCRA petitions; his fourth, filed March 9, 2012, relied on new affidavits (notably Draper’s) and claimed the Commonwealth withheld Brady material showing Norwood had sexual relationships with teenage boys (described as "homosexual ephebophilia").
The PCRA court found governmental interference (Brady suppression) and granted a new penalty-phase hearing, vacating Williams’ death sentence and staying execution. The Commonwealth appealed.
This Court initially vacated the PCRA court’s order and reinstated the death sentence; the U.S. Supreme Court granted certiorari, vacated that judgment, and remanded on due-process grounds, prompting this reexamination.
The central question on remand: whether Williams satisfied the PCRA timeliness exception for governmental interference (42 Pa.C.S. § 9545(b)(1)(i)) by showing he could not have discovered the Brady information earlier despite due diligence.
The Court concluded Williams failed to prove the governmental-interference exception because the substance of the alleged Brady information (Norwood’s sexual conduct with teenage boys) was already known or discoverable to Williams well before 2012 and was presented in prior proceedings.

Issues

Issue	Williams' Argument	Commonwealth's Argument	Held
Whether Williams met the PCRA timeliness exception for governmental interference (§ 9545(b)(1)(i)) based on alleged Brady suppression of evidence about Norwood’s sexual conduct	Draper’s 2012 affidavits (and other declarations) revealed suppressed evidence; Williams filed within 60 days and thus met the exception	Williams already knew or could have discovered the substance of the allegations earlier (trial, 1998 PCRA, federal habeas); he failed to exercise due diligence	Held for Commonwealth: Williams did not meet the governmental-interference exception; petition untimely so PCRA court lacked jurisdiction to grant relief
Whether the purportedly suppressed items (handwritten ADA note; “sanitized” Mrs. Norwood and Poindexter statements) were material Brady evidence that vindicated timeliness	The withheld/sanitized documents would have shown Norwood’s pattern with teen boys and been exculpatory and material	The items were cumulative of information already known/presented and some were vague or non-specific; thus they did not justify circumvention of the timeliness bar	Held for Commonwealth: the items were not the kind of newly discoverable evidence that prevented earlier pleading under due diligence
Whether Williams filed his 2012 PCRA within 60 days of discovering the timeliness-excepted claim (§ 9545(b)(2))	Trigger date was Draper’s Jan. 9, 2012 affidavit; petition filed March 9, 2012 (60 days) so timely	Prior knowledge (trial, 1998 PCRA, other declarations) meant the discovery date was earlier or the claim was known already	Held for Commonwealth: even accepting Draper’s affidavit date, Williams had long-known allegations that made the 2012 filing untimely to invoke the exception
Whether the PCRA court erred in vacating Williams’ death sentence and ordering a new penalty hearing	Relief was warranted if governmental interference excused the PCRA time-bar and Brady claim had merit	If timeliness exception fails, PCRA court lacked jurisdiction and its relief must be vacated	Held for Commonwealth: vacate PCRA order; reinstate death sentence (Justice Mundy would reverse and reinstate death sentence on jurisdictional ground)

Key Cases Cited

Brady v. Maryland, 373 U.S. 83 (1963) (prosecution's suppression of exculpatory evidence violates due process)
Williams v. Beard, 637 F.3d 195 (3d Cir. 2011) (federal habeas review of Williams’ ineffective-assistance claims)
Williams v. Pennsylvania, 136 S. Ct. 1899 (2016) (U.S. Supreme Court granted certiorari, vacated, and remanded the Pennsylvania Court decision on due-process grounds)
Commonwealth v. Busanet, 54 A.3d 35 (Pa. 2012) (standard of review for PCRA courts)
Commonwealth v. Cox, 146 A.3d 221 (Pa. 2016) (PCRA timeliness is jurisdictional and exceptions must be proven)
Commonwealth v. Abu-Jamal, 941 A.2d 1263 (Pa. 2008) (governmental-interference exception requires that due diligence could not have produced the claim earlier)
Commonwealth v. Morris, 822 A.2d 684 (Pa. 2003) (information available at trial cannot be recast as governmental interference to avoid PCRA time bar)
Commonwealth v. Hackett, 956 A.2d 978 (Pa. 2008) (§ 9545(b)(2) requires filing within 60 days of when the claim could have been presented)