STATE OF NEW JERSEY VS. WILLIAM BOSTONÂ (04-10-0985, CUMBERLAND COUNTY AND STATEWIDE), A-1483-15T1

Defendant William Boston was convicted (after trial) of first‑degree murder, felony murder, burglary, weapons and conspiracy offenses for the 2002 stabbing/strangulation death of R.W.; post‑merger sentence for murder was 55 years.
On direct appeal, this court affirmed convictions and rejected challenges to the admissibility of defendant's statements (Miranda waiver), evidentiary rulings, confrontation issues, hearsay, and prosecutorial conduct.
Defendant filed a pro se PCR petition on March 4, 2013; counsel submitted a supporting brief.
The PCR court denied relief in a written opinion on May 27, 2015, without an evidentiary hearing; defendant appealed.
Defendant argued trial counsel was ineffective for failing to present psychiatric/psychological/medical evidence at the Miranda hearing and also asserted procedural errors (timeliness and need for an evidentiary hearing).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of PCR petition	State: petition filed beyond Rule 3:22‑12(a)(1) limitations	Boston: sought relief despite delay; asserted excusable neglect/fundamental injustice	Held: PCR was time‑barred; defendant failed to show excusable neglect or fundamental injustice
Claim of ineffective assistance re: Miranda hearing	State: claim is precluded because the Miranda waiver issue was previously adjudicated on direct appeal	Boston: counsel was ineffective for not presenting psychiatric/medical experts at the Miranda hearing	Held: claim barred by Rule 3:22‑5 as substantially equivalent to issues decided on direct appeal; no prima facie Strickland showing
Need for evidentiary hearing	State: no hearing required where petitioner fails to make a prima facie showing of entitlement to relief	Boston: PCR court erred by denying a hearing to develop expert evidence	Held: no hearing required because defendant did not establish a prima facie case of ineffective assistance
Prejudice from alleged counsel errors	State: even if counsel erred, defendant cannot show a reasonable probability of a different outcome	Boston: expert evidence would have shown involuntariness or incompetence to waive Miranda, producing prejudice	Held: defendant failed to demonstrate Strickland prejudice; relief denied

Strickland v. Washington, 466 U.S. 668 (establishes two‑part ineffective assistance test)
Miranda v. Arizona, 384 U.S. 436 (Miranda waiver and custodial‑interrogation protections)
State v. Fritz, 105 N.J. 42 (adoption of Strickland in New Jersey)
State v. Marshall, 173 N.J. 343 (preclusion under Rule 3:22‑5 for issues previously adjudicated)
State v. McQuaid, 147 N.J. 464 (PCR is not a vehicle to relitigate direct appeal claims)
State v. Porter, 216 N.J. 343 (no evidentiary hearing required absent prima facie PCR showing)
State v. Preciose, 129 N.J. 451 (prima facie standard for evidentiary hearing in PCR proceedings)
State v. L.A., 433 N.J. Super. 1 (discusses prejudice standard under Strickland)