Commonwealth v. Robinson, A., Aplt.
139 A.3d 178
| Pa. | 2016Background
- In 1996 Antyane Robinson shot two people; one (Bass) died; Robinson was convicted of first-degree murder, attempted homicide, and sentenced to death after a penalty-phase jury found aggravators outweighed mitigators.
- Robinson’s direct appeal was denied by the Pennsylvania Supreme Court (Commonwealth v. Robinson) and certiorari to the U.S. Supreme Court was denied on January 10, 2000, making his judgment final for PCRA purposes.
- Robinson timely filed a first PCRA petition in October 2000; the PCRA court denied relief after an evidentiary hearing, and this Court affirmed in subsequent proceedings.
- In September 2013 Robinson filed a second PCRA petition more than 13 years after finality, challenging trial counsel’s effectiveness and claiming his first PCRA counsel was ineffective for failing to raise certain claims.
- Robinson did not invoke any of the PCRA’s statutory timeliness exceptions (government interference, newly discovered facts, or newly recognized retroactive constitutional rights).
- The PCRA court dismissed the 2013 petition as untimely; the Pennsylvania Supreme Court affirmed, refusing to create an equitable exception to the PCRA’s one-year time bar.
Issues
| Issue | Plaintiff's Argument (Robinson) | Defendant's Argument (Commonwealth) | Held |
|---|---|---|---|
| Whether courts may create an equitable exception to the PCRA one-year time bar to allow untimely serial petitions that challenge prior PCRA counsel’s effectiveness | Robinson argued that Martinez/Trevino justify permitting review of trial-counsel-ineffectiveness claims in a belated PCRA when initial PCRA counsel was ineffective, because otherwise there is no forum to enforce the right to effective PCRA counsel | Commonwealth argued PCRA timeliness is jurisdictional, the Legislature set exclusive exceptions, and Martinez/Trevino altered only federal habeas law and do not require changing state PCRA procedure | Court held no equitable exception exists; PCRA’s one-year limit is jurisdictional and enforceable only via statutory exceptions; petition dismissed as untimely |
| Whether claims framed as PCRA-counsel ineffectiveness can evade the PCRA time bar | Robinson asserted framing the claims as PCRA-counsel ineffectiveness should allow review despite untimeliness | Commonwealth responded that using ineffectiveness labels cannot circumvent the statutory time limits; precedent rejects such attempts | Court held allegations of PCRA-counsel ineffectiveness do not overcome jurisdictional time bar; statute governs |
| Whether Martinez and Trevino require Pennsylvania to permit late state collateral review where initial-review counsel was ineffective | Robinson urged this Court to adopt a Martinez/Trevino-style equitable rule for state collateral review | Commonwealth and court explained Martinez/Trevino apply to federal habeas procedural-default doctrine and do not create a state-law obligation to alter statutory time bars | Court held Martinez/Trevino do not compel change; federal rulings cannot override Pennsylvania’s statutory PCRA framework |
| Whether the PCRA court erred in dismissing the petition without reaching merits | Robinson argued denial foreclosed enforcement of right to effective PCRA counsel | Commonwealth argued lack of jurisdiction precluded merits review | Court held dismissal was proper because petition was filed after the one-year period and no statutory exception was pleaded or proven |
Key Cases Cited
- Commonwealth v. Robinson, 721 A.2d 344 (Pa. 1998) (affirming conviction and sentence)
- Martinez v. Ryan, 132 S. Ct. 1309 (U.S. 2012) (federal habeas procedural-default exception where initial-review collateral counsel was ineffective or absent)
- Trevino v. Thaler, 133 S. Ct. 1911 (U.S. 2013) (extending Martinez to procedural frameworks that make raising IATC on direct appeal unlikely)
- Commonwealth v. Fahy, 737 A.2d 214 (Pa. 1999) (PCRA filing period is jurisdictional and not subject to equitable tolling)
- Commonwealth v. Watts, 23 A.3d 980 (Pa. 2011) (court cannot fashion ad hoc equitable exceptions to PCRA time-bar)
- Commonwealth v. Ligons, 971 A.2d 1125 (Pa. 2009) (plurality discussing enforcement difficulties of right to effective PCRA counsel)
- Commonwealth v. Holmes, 79 A.3d 562 (Pa. 2013) (discussing Martinez and noting it does not create a constitutional right obligating states to accommodate specific procedures)
- Commonwealth v. Williams, 105 A.3d 1234 (Pa. 2014) (reiterating PCRA time restrictions are jurisdictional)