Commonwealth v. Franklin

Summary

The Pennsylvania Superior Court vacated an order granting William Franklin a new trial under the Post Conviction Relief Act and remanded for further proceedings. The court held that establishing an exception to the PCRA time bar establishes jurisdiction but does not itself establish entitlement to substantive relief. It directed the PCRA court to address Franklin’s Brady and after-discovered-evidence claims, including the admissibility of a deceased witness’s recantation under the statement-against-interest hearsay exception.

Holdings

1. The PCRA court correctly found that Franklin timely filed his petition under the newly-discovered-fact exception because he filed it within sixty days after learning of Claitt's recantation.
2. The PCRA court erred by granting a new trial solely after determining that Franklin's second PCRA petition was timely; satisfying a PCRA timeliness exception establishes jurisdiction to consider a substantive claim but does not itself establish entitlement to PCRA relief.
3. Claitt's recantation was not admissible under Pennsylvania Rule of Evidence 804(b)(3) because, when made in 2016, it did not expose him to civil or criminal liability; the statute of limitations for perjury had expired.
4. The PCRA court did not properly assess whether the circumstances of Claitt's recantation were clearly indicative of trustworthiness.

Questions Presented

1. Whether Franklin's facially untimely second PCRA petition satisfied the newly-discovered-fact or governmental-interference exceptions to the PCRA time bar.
2. Whether the PCRA court erred by treating satisfaction of a PCRA timeliness exception as an independent basis for granting a new trial without deciding the substantive PCRA claims.
3. Whether Claitt's recantation statement and video were admissible under the statement-against-interest exception to the hearsay rule.
4. Whether the circumstances surrounding Claitt's recantation clearly indicated its trustworthiness.

Disposition

vacated