Commonwealth v. Watley
153 A.3d 1034
| Pa. Super. Ct. | 2016Background
- Watley and Hayward stopped for speeding (~95 mph in 45 mph zone) on State Route 22 in Northampton County in the early morning of Feb. 14, 2009.
- Hayward used an alias (Jermaine Jones) and later identification as Randy Hayward; Hayward had an outstanding NJ warrant.
- Police discovered a firearm under a floor mat after detaining Hayward and having Watley flee on foot; additional firearms and drugs were found in the car following a search warrant.
- Hayward’s trial testimony was inconsistent with his prior sworn statement and guilty plea, which were admitted as substantive evidence at Watley’s trial.
- Watley filed a timely PCRA petition in June 2015; the PCRA court vacated Watley’s sentence based on Alleyne/Newman implications and ordered re-sentencing, while denying other PCRA relief; Watley appeals the denial of ineffective assistance claims and related issues.
- The Superior Court affirms, applying standard PCRA review and evaluating the effectiveness claims and discovery rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance from admitting prior statements | Watley argues Hayward’s prior statement and guilty plea were not inconsistent with trial testimony and should not have been admitted | Watley’s trial counsel failed to object to or appeal admission of these statements despite inconsistency | Inconsistent statements properly admitted as substantive evidence; claims fail on prong one of the ineffectiveness test |
| Ineffective assistance for failing to seek suppression | Watley contends suppression of evidence from an unconstitutional search would have yielded a different outcome | Protective search of the car for weapons was justified by totality of circumstances | No effective assistance; suppression would be unwarranted; evidence admissible |
| Investigation and trial preparation | Watley asserts inadequate pre-trial investigation, poor consultation, failure to call alibi witnesses, and failure to advise him on testifying | PCRA court credibility determinations upheld; counsel did consult and alibi witnesses lacked credibility; decision to testify rested with Watley | No deficient performance; no prejudice demonstrated |
| Fingerprint analysis and discovery on ID card | Fingerprints on the ID card would be highly incriminating or exculpatory; discovery warranted | Exceptional circumstances did not exist; no prejudice shown without actual analysis | No exceptional circumstances; no prejudice established; discovery denied |
Key Cases Cited
- Commonwealth v. Ousley, 21 A.3d 1238 (Pa.Super. 2011) (standard for review of PCRA decisions; findings supported by record)
- Commonwealth v. Knudsen, 278 A.2d 881 (Pa. 1971) (distinguishes mere failure of recollection from inconsistent prior statements)
- Commonwealth v. McCrae, 832 A.2d 1026 (Pa. 2003) (hearsay and impeachment use of prior statements; substantive evidence requirements)
- Commonwealth v. Carmody, 799 A.2d 143 (Pa.Super. 2002) (reliability requirements for admissible inconsistent prior statements as substantive evidence)
- Commonwealth v. Brown, 448 A.2d 1097 (Pa.Super. 1982) (impeachment use of prior inconsistent statements; cross-examination essential)
- Commonwealth v. Morris, 644 A.2d 721 (Pa. 1994) (protective searches of a vehicle for weapons permissible under totality of circumstances)