Commonwealth v. Williams

Summary

The Pennsylvania Superior Court affirmed the dismissal of Jermaine Williams's fifth petition under the Post-Conviction Relief Act. The court held that although Williams satisfied the newly discovered facts exception to the PCRA's jurisdictional time bar, he failed to establish that alleged police misconduct constituted qualifying after-discovered evidence likely to compel a different verdict. The court emphasized that the alleged misconduct involved other cases, was not supported by evidence of misconduct in Williams's case, and would primarily have been used for impeachment.

Holdings

1. Williams satisfied the newly discovered facts exception because he filed his claim within one year of the District Attorney's disclosure concerning Officer Norman and acted with the requisite diligence after learning of that information.
2. Williams was not entitled to PCRA relief because he failed to establish that the alleged police misconduct could be used for a purpose other than impeachment and failed to show that the evidence would likely compel a different verdict.

Questions Presented

1. Whether Williams satisfied the PCRA's newly discovered facts exception to its jurisdictional time bar.
2. Whether alleged after-discovered evidence of police misconduct satisfied the PCRA requirements for relief by being usable for a non-impeachment purpose and likely to compel a different verdict.

Disposition

affirmed