Commonwealth v. Simpson
620 Pa. 60
| Pa. | 2013

Background

  • Rasheed Simpson challenged the Philadelphia County PCRA court's dismissal of his petition for relief under 42 Pa.C.S.A. §§ 9541-46.
  • Simpson was convicted in 1997 of first-degree murder, kidnapping, robbery, conspiracy, and related offenses for the Haynes homicide and received a death sentence; direct appeal affirmed.
  • Simpson filed a PCRA petition in 2001; after briefing, the PCRA court denied relief without a hearing in 2005.
  • The Court reviews ineffective assistance, Batson, Brady, evidentiary claims, jury instructions, sentencing issues, and other constitutional challenges, with remand on some issues to develop facts.
  • The majority affirms the PCRA court on most issues, vacates and remands for further proceedings to address trial counsel’s ineffectiveness regarding witness Raheema Washington and the testimony of Cameron Thompson, and preserves remand for related factual development.
  • A dissent criticizes the PCRA court for inadequate pre-dismissal notice and deficient reasoning, urging consistent procedural compliance.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Batson claim and ineffectiveness Simpson argues purposeful discrimination in peremptory strikes and ineffective trial counsel for not challenging them. Commonwealth contends no actual discrimination established and that some claims are waived; record insufficient for prima facie Batson, and McMahon tape is not dispositive. Batson claim rejected; no demonstrable actual discrimination; related ineffectiveness claim vacated for remand.
Brady/Impeachment evidence Failure to disclose victim’s full criminal history, Hall’s charges, and Copper’s status as a paid informant violated Brady; ineffective assistance for trial counsel’s failure to pursue Brady-related impeachment. Evidence was cumulative or not in Commonwealth's possession; no proven deal or prejudice; defense had access to some impeachment material. Brady claims rejected; no prejudice shown; some issues remanded for further factual development as to impeachment strategy.
Impeachment of Raheema Washington and witness Thompson Trial counsel should have impeached Washington with bias/motive and presented Cameron Thompson to rebut her testimony. Claims inadequately developed; affidavit from Thompson untimely; cannot prove prejudice or strategic reason for not presenting. Remanded for evidentiary hearing on counsel’s effectiveness regarding Washington impeachment and Thompson witness presentation.
Investigator conflict of interest Investigator's dual representation of co-defendant created conflict prejudicing Simpson’s defense. No automatic prejudice presumption for investigators; lack of concrete showing of actual prejudice. Claim rejected; no prejudice proven; no remand warranted.
Mitigating evidence at penalty phase Counsel failed to investigate/present substantial mitigating evidence (traumatic background, cognitive impairment, mental health). Evidence presented was substantial and cumulative; no proven prejudice from lack of additional mitigation. No prejudice shown; no evidentiary hearing required; claim dismissed.

Key Cases Cited

  • Strickland v. Washington, 466 U.S. 668 (1984) (three-prong performance and prejudice test for ineffective assistance)
  • Pierce, 515 Pa. 153 (1987) (Pennsylvania test for ineffectiveness under Strickland framework)
  • Batson v. Kentucky, 476 U.S. 79 (1986) (prosecutor must show race-neutral basis for peremptory challenges after prima facie showing)
  • Brady v. Maryland, 373 U.S. 83 (1963) (duty to disclose favorable exculpatory/impeachment material)
  • Kyles v. Whitley, 514 U.S. 419 (1995) (material evidence disclosure and prejudice standard in Brady context)
  • Sattazahn, 597 Pa. 648 (2008) (Brady duty and materiality standards in Pa. Supreme Court context)
  • Giglio v. United States, 405 U.S. 150 (1972) (impeachment evidence and witness credibility considerations under Brady)
  • Lambert, 584 Pa. 461 (2005) (Brady materiality and cumulative evidence considerations in Pa.)
  • Rainey, 593 Pa. 67 (2007) (prejudice standard for mitigating-instruction-related claims)
  • Harrington v. Richter, 131 S. Ct. 770 (2011) (standard for prejudice in capital sentencing under Strickland context)
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