Commonwealth v. Williams
624 Pa. 405
| Pa. | 2014Background
- In 1995 James T. Williams was convicted of first‑degree murder and sentenced to death; his conviction and sentence were affirmed on direct appeal.
- Williams filed a capital PCRA petition; standby counsel (FCDO) aided an amended petition and pursued discovery seeking the trial prosecutor’s notes for four co‑conspirator witnesses.
- The Lehigh County PCRA court ordered the Commonwealth to produce “all notes” of former ADA Maria Dantos concerning interviews, witness preparation, and examination outlines for those witnesses; the order was entered without full adversary input and over the Commonwealth’s objections.
- The Commonwealth appealed, arguing the notes are protected by the work‑product doctrine and that Williams failed to show the “good cause” required for discovery under Pa.R.Crim.P. 902(E)(2).
- The Supreme Court considered (1) whether the PCRA discovery order is immediately appealable as a collateral order under Pa.R.A.P. 313 and (2) whether the PCRA court abused its discretion in ordering disclosure.
- The Court held the discovery order was appealable under Rule 313, found the PCRA court abused its discretion for failing to find good cause (and for inadequately addressing work‑product protections), vacated the order, and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Williams) | Held |
|---|---|---|---|
| Appealability under Pa.R.A.P. 313 | Order overruling work‑product claim is separable, important, and irreparably lost if disclosed; collateral order appeal permitted | Relies on Mohawk; argues discovery for Brady material is routine and not collaterally appealable; PCRA court should control discovery | Appealable under Rule 313 where order compels production of materials that arguably are work product; collateral order test satisfied |
| Work‑product protection for prosecutor’s notes | Notes (interview summaries, prep outlines) are core work product; disclosure would chill trial prep and is presumptively protected | Argues Brady obligates disclosure of prosecutor notes relating to witness inconsistencies and that notes may show exculpatory/impeachment material | Court did not decide absolute protection but recognized notes are the sort of material usually protected; work‑product claim was colorable and supported appealability |
| Good cause under Pa.R.Crim.P. 902(E)(2) for PCRA discovery | Williams failed to show specific, non‑speculative facts or that requested notes existed or contained Brady material; prosecutor testified she had no such notes and would have disclosed exculpatory material | Williams argued prosecutor’s testimony that witness statements changed gave good cause to inspect notes and that Brady supports access | PCRA court abused discretion: Williams offered only speculation and the PCRA court failed to apply the good‑cause standard or meaningfully address work‑product assertions; remand required |
| Remedy / disposition | Urged reversal of order permitting disclosure | Sought enforcement of discovery order to review prosecutor’s files | Supreme Court vacated the PCRA court’s disclosure order and remanded for final PCRA resolution (and directed PCRA court to address FCDO participation) |
Key Cases Cited
- Commonwealth v. Williams, 586 Pa. 553, 896 A.2d 523 (Pa. 2006) (direct‑appeal decision describing trial facts)
- Commonwealth v. Harris, 612 Pa. 576, 32 A.3d 243 (Pa. 2011) (orders overruling privilege claims are immediately appealable)
- Commonwealth v. Kennedy, 583 Pa. 208, 876 A.2d 939 (Pa. 2005) (work‑product and collateral‑order analysis)
- Commonwealth v. Dennis, 580 Pa. 95, 859 A.2d 1270 (Pa. 2004) (PCRA discovery and prosecutor note privilege)
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecutorial duty to disclose exculpatory evidence)
- Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100 (U.S. 2009) (federal collateral‑order limits on privilege appeals)
- Pennsylvania v. Ritchie, 480 U.S. 39 (U.S. 1987) (limits on defendant’s right to search prosecutor files; Commonwealth first determines Brady disclosure)
- Osborne v. District Attorney’s Office for Third Judicial Dist., 557 U.S. 52 (U.S. 2009) (Brady does not define scope of post‑conviction discovery)
- Hickman v. Taylor, 329 U.S. 495 (U.S. 1947) (foundational work‑product doctrine)
- Nobles v. United States, 422 U.S. 225 (U.S. 1975) (work‑product protections for mental impressions)