Commonwealth v. Sneed, 45 A.3d 1096

Appellant Willie Sneed was convicted of first-degree murder and an instrument-of-crime on March 14, 1985, after fatally shooting Hawkins when he discovered cocaine sold as aspirin.
Penalty phase yielded two aggravating factors and no mitigators, resulting in a death sentence.
PCRA petition filed January 16, 1997; initially not appointed counsel and petition not reviewed; execution scheduled for September 14, 1999.
Amended PCRA petition filed April 12, 2000 raising 25 claims; evidentiary hearing granted on Batson claim and penalty-phase ineffectiveness.
PCRA court granted new trial on Batson claim and new penalty hearing on ineffectiveness; Commonwealth appealed, this Court partially reversed in 2006.
PCRA court later addressed remaining guilt-phase claims, and the Pennsylvania Supreme Court ultimately affirmed the denial of PCRA relief and remanded for a new penalty phase.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for failure to present mitigation at penalty phase	Sneed contends counsel failed to investigate and present mitigating evidence.	Commonwealth argues counsel acted within trial strategy and and there was no prejudice.	Denied relief; strategic decisions acceptable; no prejudice shown.
Prosecutorial misconduct at closing	Sneed asserts multiple improper prosecutorial remarks biased the jury.	Commonwealth maintains remarks were proper or responsive and not reversible error.	Denied relief; arguments upheld as proper closing and responsive advocacy.
Jury interference due to outside influence	Extraneous influence by Mrs. D'Amore affected jury impartiality.	Record shows influence were minimal and not prejudicial; no error.	Denied relief; no reasonable likelihood of prejudice established.
Brady v. Maryland violation	Commonwealth allegedly suppressed exculpatory information.	No specific withheld evidence identified; not a fishing expedition for discovery.	Denied relief; no proof of suppressed material exculpatory evidence.
Treaty bar (ICCPR) on PCRA review	ICCPR bars state procedural rules from denying review.	Breard and supranational law permit state procedural rules to govern; ICCPR claim futile.	Denied relief; treaty-based theory rejected.

Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prosecutorial race-neutral strikes; retroactive Batson analysis)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (test for ineffective assistance of counsel)
Commonwealth v. Hughes, 865 A.2d 761 (Pa. 2004) (ineffectiveness standard for PCRA claims in PA; waiver rules)
Commonwealth v. Fletcher, 896 A.2d 508 (Pa. 2006) (remand for resolution of unresolved PCRA claims; guilt-phase precedes resentencing)
Breard v. Greene, 523 U.S. 371 (U.S. 1998) (treaty interpretation; non-self-executing treaties and state procedural rules)