J.J. Daniels v. Adams County Dist. Atty.'s Office, 211 C.D. 2024

Jerry Jeron Daniels was convicted by jury in Adams County, Pennsylvania, in 2006 for rape and related charges, and sentenced to 11-22 years' imprisonment.
Daniels filed a habeas corpus petition in July 2023 alleging that his conviction and detention were the result of fraud and violations of due process.
The Commonwealth filed preliminary objections (POs), primarily arguing the petition was untimely and that relief was only available under the Post Conviction Relief Act (PCRA).
Daniels was permitted to amend his petition but failed to invoke any statutory exceptions to the PCRA’s jurisdictional time bar, filing his Amended Petition in December 2023.
The trial court sustained the Commonwealth's POs and dismissed Daniels' Amended Petition with prejudice, holding that it lacked jurisdiction because the petition was untimely under the PCRA.
Daniels appealed to the Commonwealth Court, which affirmed the trial court’s order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Trial court jurisdiction over habeas petition	Daniels: Court has original jurisdiction over habeas corpus and claims not cognizable under PCRA	Commonwealth: Claims governed solely by PCRA and are untimely, court lacks jurisdiction	Court agreed with Commonwealth: Claims are subject to PCRA, petition untimely, no jurisdiction
Claims of illegal detention due to alleged procedural irregularities (no warrant, no complaint, no arraignment)	Daniels: Unlawful detention for over 18 years due to procedural defects, voiding conviction	Commonwealth: Such defects are subject to PCRA; Daniels did not plead exceptions to time bar	Court: Procedural claims are governed by PCRA, none of the exceptions were pled, petition dismissed
Application of statutory time bar and exceptions to PCRA	Daniels: Did not acknowledge or properly argue any exceptions	Commonwealth: Daniels failed to timely file or plead exceptions; PCRA time bar is jurisdictional	Court: Daniels did not invoke any dormant exceptions — petition untimely, no jurisdiction
Appropriate appellate jurisdiction and transfer versus dismissal	Daniels: Did not contest; argued merits	Commonwealth: Commonwealth Court lacked appellate jurisdiction; case should be dismissed not transferred for untimeliness	Court: By rule, jurisdiction vested due to no timely objection from Commonwealth, but dismissal appropriate due to untimeliness

Brown v. Clark, 184 A.3d 1028 (Pa. Cmwlth. 2018) (setting standard for appellate review of orders sustaining preliminary objections)
Moss v. SCI – Mahanoy Superintendent Pa. Bd. of Prob. & Parole, 194 A.3d 1130 (Pa. Cmwlth. 2018) (jurisdictional deadline under PCRA is strictly interpreted)
Bethlehem Twp. v. Emrick, 465 A.2d 1085 (Pa. Cmwlth. 1983) (failure to object to appellate jurisdiction may result in decision on the merits)