Commonwealth v. Morris, 573 Pa. 157

Summary

The Supreme Court of Pennsylvania held that stays of execution sought in connection with second or subsequent collateral proceedings must comply with the Post-Conviction Relief Act, including 42 Pa. C.S. § 9545(c). The court rejected an inherent-power and non-frivolous-claim standard for granting such stays in this context. It further concluded that claims of PCRA counsel ineffectiveness did not satisfy the statutory timeliness exception and declined to exercise jurisdiction over the untimely petition.

Holdings

1. Section 9545(c) applies to all Pennsylvania courts, including the Supreme Court of Pennsylvania, and governs stays of execution in second or subsequent PCRA proceedings.
2. The court rejected Morris's request for a general inherent-power or nonfrivolous-claim standard for stays in successive PCRA proceedings and held that the heightened statutory standard controls in this case.
3. A claim that prior PCRA counsel was ineffective does not constitute a newly discovered fact and does not save an otherwise untimely PCRA petition.
4. The court lacked jurisdiction to review Morris's second PCRA petition because it was untimely and Morris failed to establish a valid statutory exception.

Questions Presented

1. Whether 42 Pa.C.S. § 9545(c) governs the Supreme Court of Pennsylvania's authority to issue a stay of execution while a second or subsequent PCRA petition is pending.
2. Whether the Supreme Court possesses inherent authority to issue a stay of execution outside the requirements of § 9545(c) to preserve the status quo or review nonfrivolous claims.
3. Whether Morris's untimely second PCRA petition satisfied an exception to the PCRA time bar based on alleged ineffective assistance of PCRA counsel, newly discovered evidence, or governmental interference.
4. Whether the court had jurisdiction to consider the substantive claims in Morris's second PCRA petition.

Disposition

other