Commonwealth v. Williams

Summary

The Supreme Court of Pennsylvania considers the Commonwealth's appeals from an order granting Terrance Williams post-conviction relief and a new penalty-phase trial. The opinion concludes that the Commonwealth willfully suppressed material exculpatory evidence concerning the victim's alleged sexual conduct and that the suppression prejudiced Williams under Brady v. Maryland. The court affirms the PCRA court's determination granting relief and a new penalty phase.

Holdings

1. A properly pleaded Brady claim may satisfy the PCRA governmental-interference exception when governmental interference prevented the petitioner from discovering and presenting the claim earlier and the petitioner could not have discovered the interference through reasonable diligence. Williams satisfied those requirements.
2. The Commonwealth violated Brady by willfully suppressing favorable evidence, including sanitized witness statements and reports concerning Norwood's sexual improprieties and the circumstances of the offense.
3. The Commonwealth's suppression was material and prejudicial because disclosure could have enabled competent defense counsel to alter trial preparation and strategy and could have caused the jury to view the offense and Williams's conduct through a mitigating lens.
4. The appellate court must defer to the PCRA court's supported factual and credibility findings and may not conduct its own fact-finding in contradiction to those findings.

Questions Presented

1. Whether Williams's fourth PCRA petition satisfied the governmental-interference exception to the PCRA's one-year time bar.
2. Whether the Commonwealth violated Brady by willfully suppressing material exculpatory and impeachment evidence concerning Amos Norwood's sexual misconduct and related evidence.
3. Whether the suppression prejudiced Williams during the penalty phase and warranted a new penalty-phase trial.
4. Whether the court should defer to the PCRA court's factual and credibility findings.

Disposition

affirmed