Commonwealth v. Jones, 210 A.3d 1014

In July 2008 two people (Sonsiarae Watts and Dahl Palm) were shot dead in Watts' home; appellant (Jones) was charged with two counts of first‑degree murder, burglary, and a firearms offense and convicted by a jury.
At trial Jones testified he was at home asleep/ watching TV (an alibi); defense counsel did not request an alibi jury instruction and did not object to its omission.
Trial evidence included threats by Jones to the victims, gunshot‑residue on Jones’s clothing, testimony about attempts to obtain a gun, neighborhood witness descriptions of a man leaving the scene, and conflicting defense testimony (including lack of corroboration for Jones’s alibi).
On PCRA review Jones argued counsel was ineffective for failing to request or object to the omitted alibi instruction; the PCRA court and Superior Court denied relief.
The Pennsylvania Supreme Court granted review limited to whether counsel’s omission rendered representation ineffective and whether Jones was prejudiced such that a new trial was required.

Issue	Plaintiff's Argument (Jones)	Defendant's Argument (Commonwealth)	Held
Whether counsel was ineffective for not requesting an alibi instruction	Counsel’s omission lacked reasonable basis and deprived Jones of a jury explanation that an uncorroborated alibi can create reasonable doubt	Counsel argued Jones cannot show prejudice given the strength of the Commonwealth’s case and that the general reasonable‑doubt charge covered the burden issue	Counsel lacked a reasonable basis for omission (Pierce prong 2 not met), but Jones failed to prove prejudice (no reasonable probability of different outcome); conviction affirmed

Commonwealth v. Pierce, 567 Pa. 186 (established three‑prong test for ineffective assistance: merit, reasonable basis, prejudice)
Commonwealth v. Hawkins, 586 Pa. 366 (abrogated per se rule for omitted alibi instruction; counsel may have a reasonable basis—case‑by‑case inquiry)
Commonwealth v. Roxberry, 529 Pa. 160 (recognizes uncorroborated testimony can constitute an alibi; earlier expressed strong criticism of failures to charge alibi)
Commonwealth v. Mikell, 556 Pa. 509 (reinforces that all Pierce prongs must be satisfied for counsel's failure to request alibi charge)
Strickland v. Washington, 466 U.S. 668 (federal standard for prejudice in ineffective assistance claims; review totality of evidence)
Commonwealth v. Laird, 632 Pa. 332 (prejudice requires reasonable probability that, but for error, outcome would differ)
Commonwealth v. Spotz, 582 Pa. 207 (prejudice analysis considers totality of the evidence before the jury)