Commonwealth v. Steele, 599 Pa. 341

Summary

The Supreme Court of Pennsylvania reviews Roland William Steele’s appeal from the denial of post-conviction relief following his convictions for three first-degree murders, robbery, and theft. The court addresses claims concerning expert hair-analysis evidence, discovery, trial counsel’s effectiveness, and waiver, and affirms the PCRA court’s denial of relief.

Holdings

1. A PCRA petitioner must prove entitlement to relief by a preponderance of the evidence, and claims that could have been raised previously are waived; the relaxed waiver doctrine does not apply in capital PCRA appeals.
2. A petitioner claiming ineffective assistance must plead and prove arguable merit, the absence of a reasonable basis for counsel's conduct, and prejudice; an undeveloped claim that does not meaningfully address all three prongs does not warrant relief.
3. Counsel's brief penalty-phase closing argument and departure from the courtroom did not constitute a complete denial of counsel under United States v. Cronic; Steele was required to prove prejudice under Strickland.
4. Steele failed to establish that counsel were ineffective for not presenting additional evidence concerning his impoverished and difficult childhood.
5. Steele failed to establish that counsel were ineffective for not investigating or presenting additional mental-health mitigation.
6. Steele's Atkins claim was not properly before the court on this PCRA appeal and was dismissed without prejudice to presentation in a subsequent PCRA petition subject to the statutory time-bar exceptions.

Questions Presented

1. Whether Steele's claims concerning the admission and reliability of hair-comparison evidence were waived under the PCRA.
2. Whether trial and appellate counsel were ineffective concerning the hair evidence, discovery, expert assistance, voir dire, identification testimony, jury instructions, prosecutorial argument, and jury deliberations.
3. Whether the PCRA court properly denied relief on Steele's claim that penalty-phase counsel was ineffective under Strickland or that counsel's performance constituted a complete denial of counsel under Cronic.
4. Whether counsel was ineffective for failing to investigate and present life-history, mental-health, and prison-conduct mitigating evidence.
5. Whether Steele's Atkins claim was properly raised in the PCRA appeal or had to be presented in a subsequent PCRA petition.

Disposition

affirmed