Commonwealth v. Brown
143 A.3d 418
| Pa. Super. Ct. | 2016Background
- Dwayne Brown was convicted of first-degree murder and related offenses after a 1997 jury trial and received a life sentence; his convictions became final in 2000 after direct review concluded.
- Brown filed multiple prior PCRA petitions (first in 2000, others in 2005 and 2007); earlier petitions raised after-discovered evidence and recantation claims and were denied or held previously litigated.
- In 2013 Brown filed a fourth PCRA petition alleging a Brady claim and actual innocence based on recantations and other evidence.
- The Commonwealth moved to dismiss; the PCRA court issued a Rule 907 notice and dismissed the petition as untimely on March 20, 2015 for lack of jurisdiction.
- Brown appealed, arguing (1) it is unconstitutional to apply the PCRA timeliness bar to a Brady actual innocence gateway claim and (2) the PCRA court denied due process by dismissing without full record review.
- The Superior Court affirmed, holding federal habeas developments (e.g., McQuiggan) do not alter Pennsylvania’s PCRA time-bar jurisprudence and Brown failed to establish a statutory exception to timeliness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether applying the PCRA timeliness provisions to a Brady-based actual innocence claim is unconstitutional | Brown: McQuiggan allows an actual-innocence gateway to overcome federal statute of limitations; applying PCRA time-bar to Brady claims violates due process | Commonwealth/PCRA court: Pennsylvania PCRA time limits and exceptions control; federal habeas developments are irrelevant to state PCRA timeliness | Held: PCRA time-bar applies; McQuiggan and other federal decisions do not affect PCRA exceptions; petition untimely and no exception proven, so court lacked jurisdiction |
| Whether dismissal without review of the entire record denied due process | Brown: PCRA court failed to review full record and thus violated state and federal due process | Commonwealth: Court lacked jurisdiction due to untimeliness, so merits review (and any alleged record-review error) is unavailable | Held: Because dismissal was for lack of jurisdiction, Brown's procedural-due-process claim fails |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecutorial suppression of exculpatory evidence violates due process)
- McQuiggin v. Perkins, 133 S. Ct. 1924 (2013) (actual-innocence gateway can overcome federal habeas statute of limitations)
- Commonwealth v. Saunders, 60 A.3d 162 (Pa. Super. 2013) (federal habeas developments do not change Pennsylvania PCRA time-bar application)
- Commonwealth v. Porter, 5 A.3d 4 (Pa. 2010) (applying PCRA time-bar to Brady claims)
- Commonwealth v. Murray, 753 A.2d 201 (Pa. 2000) (PCRA one-year filing requirement is jurisdictional)