Commonwealth v. Mitchell, W., Aplt
105 A.3d 1257
| Pa. | 2014Background
- Appellant Wayne Cordell Mitchell was condemned to death for the September 10, 1997 murder of Robin Little following a 1997 rape/attack; conviction and death sentence upheld on direct appeal (Mitchell I).
- Mitchell filed a timely PCRA petition in 2007 challenging counsel’s performance and other issues; a five-day evidentiary hearing occurred in 2012, and the PCRA court denied relief.
- The PCRA court applied a Strickland-like standard for ineffectiveness and deferred certain claims per Grant v. Wharton lineage, reviewing credibility and law de novo on appeal.
- Mitchell confessed to police after waiving Miranda rights at the homicide office; suppression of this confession was denied at trial and on direct appeal.
- Appellant claimed multiple ineffective-assistance theories (suppression, guilty-plea advice, witness impeachment, Brady violation, failure to share documents with a psychiatric expert, mitigation strategy); the Supreme Court affirmed denial of PCRA relief.
- The Court held the PCRA court’s credibility findings are binding and that Mitchell failed to prove prejudice on any individual or cumulative basis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance for suppression of confession | Mitchell argues trial counsel should have presented evidence of diminished capacity | Court found no abuse of discretion; waiver was knowing and intelligent | No relief; waiver valid; no prejudice |
| Guilty-plea advice ineffective assistance | Counsel allegedly advised pleading to minimize or bar evidence of sexual offenses | PCRA court found counsel advised to minimize exposure, not to bar evidence | No relief; no prejudice shown |
| Failure to interview key witness Britton to impeach testimony | Interview would have revealed memory and sleep-related recollection issues | PCRA court credited witnesses’ demeanor and found no pretrial disclosure would have changed outcome | No relief; no prejudice |
| Brady violation regarding Britton’s initial police contact | Prosecutor suppressed Britton’s initial police contact records | Evidence did not exist; no Brady material existed | No relief; no Brady violation |
| Failure to provide Britton/Little documents to Bernstein; impact on guilt/penalty | Non-disclosed documents would have undermined Bernstein’s opinions | Even with documents, prejudice not shown; Bernstein maintained opinions; trial strategy reasonable | No relief; no prejudice in guilt or penalty phases |
Key Cases Cited
- Commonwealth v. Grant, 813 A.2d 726 (Pa. 2002) (deferred ineffectiveness claims to collateral review)
- Commonwealth v. Robinson, 82 A.3d 998 (Pa. 2013) (standard for reviewing PCRA findings; credibility binding)
- Commonwealth v. Sneed, 45 A.3d 1108 (Pa. 2012) (three-pronged ineffectiveness test; prejudice required)
- Commonwealth v. Busanet, 54 A.3d 35 (Pa. 2012) (three-pronged Strickland-style test in PA)
- Commonwealth v. Spotz, 18 A.3d 244 (Pa. 2011) (mitigation-cumulative prejudice guidance; reasonableness of strategy)
- Commonwealth v. Weiss, 81 A.3d 767 (Pa. 2013) (relevance of prior convictions to rebut mitigating factors)