Commonwealth v. Breakiron

Summary

The Supreme Court of Pennsylvania affirmed the dismissal of Mark Breakiron's second petition for post-conviction relief as untimely under the Pennsylvania Post Conviction Relief Act. The court held that the petition did not satisfy any statutory exception to the one-year filing limit, including exceptions based on alleged Brady violations, newly discovered evidence concerning jury deliberations, or ineffective assistance of counsel.

Holdings

1. The PCRA's time restrictions are jurisdictional and require any PCRA petition, including a second or subsequent petition, to be filed within one year after the judgment becomes final unless a statutory exception is proven.
2. A properly pleaded Brady claim may fall within the governmental-interference exception, but the petitioner must also satisfy the requirement that the petition be filed within sixty days of the date the claim could have been presented.
3. A later recognition by current counsel of a possible claim based on jury influences occurring years earlier is not a newly discovered fact under the PCRA's after-discovered-evidence exception.
4. Ineffective-assistance claims and the alleged importance or constitutional magnitude of the underlying violations do not exempt a PCRA petition from the PCRA's jurisdictional time requirements.

Questions Presented

1. Whether Breakiron's second PCRA petition was timely under the PCRA's one-year filing limitation.
2. Whether the alleged suppression of Brady material satisfied the governmental-interference exception to the PCRA time bar.
3. Whether juror affidavits concerning jury deliberations and the meaning of a life sentence constituted newly discovered facts satisfying the after-discovered-evidence exception.
4. Whether ineffective-assistance claims or the alleged magnitude of the constitutional violations could excuse an otherwise untimely PCRA petition.
5. Whether the common pleas court properly dismissed the petition for lack of jurisdiction.

Disposition

affirmed