Commonwealth v. Miner
44 A.3d 684
| Pa. Super. Ct. | 2012Background
- Miner was convicted of six sex offenses with multiple complainants.
- PCRA petition claimed trial counsel ineffective for alibi notice/witnesses, alibi documents, and rape shield issues.
- PCRA court dismissed as vague and undeveloped; lacked identified witnesses and supporting documents.
- PCRA court questioned whether alibi witnesses existed, were available, or could testify; petition lacked specificity.
- Appellant proceeded pro se post-remand; Supreme Court instructed counsel to handle pro se pleadings and barred self-representation after counseled brief.
- Superior Court affirmed, holding petitioner failed to demonstrate error or entitlement to relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel was ineffective for failing to file alibi notice | Miner | Commonwealth | No merit; insufficient specificity and lack of demonstrated prejudice. |
| Whether trial counsel was ineffective for not presenting alibi witnesses or documents | Miner | Commonwealth | No merit; petition undeveloped and failed to identify witnesses or documents. |
| Whether use of rape shield or impeachment evidence was incorrectly handled | Miner | Commonwealth | No merit; petition failed to articulate applicable exceptions and evidence to impeach. |
Key Cases Cited
- Commonwealth v. Cox, 603 Pa. 223 (2009) (ineffectiveness standard requires merit, basis, and prejudice)
- Commonwealth v. Clark, 599 Pa. 204 (2008) (witness-foundation and prejudice requirements for ineffective assistance claims)
- Commonwealth v. Burns, 988 A.2d 684 (Pa.Super.2009) (rape shield exceptions may render otherwise inadmissible evidence admissible)
- Commonwealth v. Battle, 879 A.2d 266 (Pa.Super.2005) (remand when reviewing remanded PCRA petitions)