Commonwealth v. Woods
179 A.3d 37
Pa. Super. Ct.2017Background
- Woods was convicted of second-degree murder in 1981 and sentenced to life imprisonment.
- Judgment became final after direct review and U.S. Supreme Court denial in 1984, triggering PCRA time limits.
- Woods’ first PCRA petition was untimely and the 1995 amendments provided a transitional grace period for pre-1996 final judgments.
- Woods had multiple prior filings, including a 2012 pro se PCRA petition and a 2016 pro se habeas petition, with counsel later appointed and/or withdrawn.
- The current petition, filed March 18, 2016, challenged Miller/Montgomery/Alleyne-type claims but was filed beyond the time bar, with attempts to invoke exceptions.
- The PCRA court dismissed the petition as untimely; Woods appeals, arguing retroactive rights and illegal-sentence theories warrant relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Woods' PCRA petition timely under 42 Pa.C.S. §9545(b)? | Untimely but seeks 9545(b)(1)(iii) retroactivity. | Petition untimely with no proven exception. | Untimely; no applicable exception proven. |
| Can Miller/Alleyne retroactivity or new-right theories save the petition under 9545(b)(1)(iii)? | Alleyne/Montgomery/Miller retroactively applicable; supports relief. | Miller not applicable to a defendant over 18; Alleyne retroactivity not retroactive on collateral review; Montgomery does not save delay. | No retroactive relief; Miller not applicable; petition remains untimely. |
| Does Vasquez-type reasoning for illegal-sentence claims override the PCRA time bar? | Vasquez supports reviewing illegal-sentence claims despite timeliness. | Illegal-sentence challenge does not circumvent timeliness and Fahy requires timeliness first. | Vasquez not controlling; timeliness controls. |
| Is Woods' notice of appeal timely and properly filed under the prison mailbox rule? | Mailbox rule makes notice timely despite initial filing concerns. | Appeal timeliness contested due to docket and Pa.R.A.P. timing rules. | Notice treated as timely under prison mailbox rule. |
Key Cases Cited
- Commonwealth v. Vasquez, 560 Pa. 381, 744 A.2d 1280 (2000) (illegal-sentence challenges and PCRA review considerations)
- Miller v. Alabama, 557 U.S. 460, 129 S. Ct. 235 (2012) (2012) (mandatory life without parole for juveniles unconstitutional; retroactivity debated)
- Montgomery v. Louisiana, 136 S. Ct. 718, 193 L. Ed. 2d 599 (2016) (retroactive application of Miller to collateral review)
- Alleyne v. United States, 133 S. Ct. 2151, 186 L. Ed. 2d 105 (2013) (any fact increasing mandatory minimum is an element requiring jury trial)
- Commonwealth v. Fahy, 558 Pa. 313, 737 A.2d 214 (1999) (illegality of sentence claims still subject to PCRA time limits)
- Commonwealth v. Secreti, 134 A.3d 77 (Pa. Super. 2016) (timeliness calculation for Montgomery timing in Pennsylvania)