Commonwealth v. Matias
63 A.3d 807
| Pa. Super. Ct. | 2013Background
- Matías was charged in 2007 with IDSI, aggravated indecent assault, indecent assault, and corruption of minors related to alleged acts by him toward RJ and K, a neighbor and friend of Matías’s daughter, in the basement of Matías’s home.
- After trial, Matías was convicted on the charged counts; in 2009 his attorney moved for extraordinary relief alleging weight of the evidence issues and ineffective representation, and the case proceeded with LaTour as trial counsel.
- On September 8, 2009, the trial court denied relief and sentenced Matías to a mandatory minimum on IDSI and concurrent terms on the other counts; no direct appeal was filed.
- Matías filed a PCRA petition in 2009; the PCRA court conducted an evidentiary hearing and on December 7, 2010 granted the petition, vacated the judgment, and awarded a new trial on grounds of ineffective assistance and weight of the evidence.
- The Commonwealth appealed under 42 Pa.C.S.A. § 9545; the Superior Court majority affirmed the PCRA relief, while Judge Mundy dissented, arguing against the ineffectiveness finding and weight-of-the-evidence relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel was ineffective for not calling K as a witness. | Commonwealth argues K’s testimony could have corroborated R and undermined Matías. | Matías’s counsel had a reasonable trial strategy not to call K due to her age and potential harm; K’s testimony would not have helped Matías. | PCRA relief upheld; failure to call K was prejudicial and lacked a reasonable basis. |
| Whether trial counsel was ineffective for not introducing photographs showing no bathroom in the basement. | Commonwealth contends photos were unnecessary because the basement bathroom issue was contested or conceded. | Matías contends the photos would have undermined R’s credibility and the defense’s theory. | PCRA relief upheld; counsel’s failure to introduce the photos prejudiced Matías. |
| Whether the weight-of-the-evidence claim is cognizable under the PCRA. | Commonwealth asserts weight-of-the-evidence claims can be reviewed under PCRA. | Matías contends the weight issue supports PCRA relief. | Weight-of-the-evidence claim is not cognizable under the PCRA and is waived. |
Key Cases Cited
- Commonwealth v. Johnson, 966 A.2d 523 (Pa. 2009) (highly deferential standard for PCRA rulings; plenary review of legal issues)
- Commonwealth v. Steele, 961 A.2d 786 (Pa. 2008) (ineffective-assistance standard for PCRA claims)
- Commonwealth v. Sneed, 45 A.3d 1096 (Pa. 2012) (witness-availability and prejudice framework under Strickland)
- Commonwealth v. Lauro, 819 A.2d 100 (Pa. Super. 2003) (trial-strategy defense for uncalled witnesses)
- Commonwealth v. Dennis, 950 A.2d 945 (Pa. 2008) (prejudice prong of ineffective assistance standard)
- Commonwealth v. Williams, 899 A.2d 1060 (Pa. 2006) (reasonableness of trial strategy; potential success of alternatives)
- Commonwealth v. Hammond, 964 A.2d 894 (Pa. 2009) (trial-strategy considerations in witness decisions)
- Commonwealth v. Miller, 987 A.2d 638 (Pa. 2009) (prejudice required for PCRA relief; standard for ineffectiveness)