Commonwealth v. Williams
35 A.3d 44
| Pa. Super. Ct. | 2011Background
- In 1999, two men robbed Elizabeth Pharmacy in Pittsburgh; a knife-wielding man and a gunman demanded money.
- A hat/wig and a bandana were left behind; witnesses identified Williams as involved in the robbery.
- Williams was convicted of robbery, aggravated assault, and conspiracy, and sentenced to 21–56 years in 2000.
- Hair from the hat/wig was presented at trial and argued to be consistent with Williams; defense cross-examined.
- Williams’ first PCRA petition (2003) was denied in 2004; the denial was affirmed in 2006.
- Williams filed a second PCRA petition (March 25, 2010) seeking DNA testing under 42 Pa.C.S.A. § 9543.1; the court dismissed it, and the Superior Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the PCRA petition was timely under § 9543.1 | Williams argues DNA testing tolls timeliness and supports relief | Commonwealth contends petition untimely and DNA relief not jurisdictional | Petition untimely; DNA testing does not excuse timeliness |
| Whether DNA testing could exculpate Williams | Hair testing could establish innocence if exculpatory | Testing would not reasonably establish innocence given other trial evidence | DNA testing would not create a prima facie case of actual innocence |
Key Cases Cited
- Commonwealth v. Smith, 889 A.2d 582 (Pa.Super.2005) (requires prima facie showing that testing could establish actual innocence)
- Commonwealth v. Weeks, 831 A.2d 1194 (Pa.Super.2003) (DNA testing motion separate from PCRA; timing rules applied)
- Commonwealth v. Conway, 14 A.3d 101 (Pa.Super.2011) (one-year PCRA bar does not apply to DNA testing motions)
- Commonwealth v. Perry, 959 A.2d 932 (Pa.Super.2008) (denial of DNA testing when timing criteria not met)
- Commonwealth v. Brooks, 875 A.2d 1141 (Pa.Super.2005) (DNA claims are distinct from PCRA claims; sequence matters)
- Commonwealth v. Gamboa-Taylor, 562 Pa. 70 (Pa.2000) (timeliness and extraordinary claims; ineffective counsel context varies)
- Commonwealth v. Bennett, 593 Pa. 382 (Pa.2007) (strict due diligence; 60-day rule for after-discovered facts exception)
- Commonwealth v. Vega, 754 A.2d 714 (Pa.Super.2000) (strict enforcement of PCRA time limits and exceptions)
- Commonwealth v. Hackett, 598 Pa. 350 (Pa.2009) (jurisdictional time limits govern PCRA petitions)
- Commonwealth v. Robinson, 575 Pa. 500 (Pa.2003) (PCRA petition finality and jurisdictional constraints)