Commonwealth, Aplt. v. Williams, C.
636 Pa. 105, 141 A.3d 440 (2016)
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Rule of Law:
Appellate counsel provides ineffective assistance by failing to raise a meritorious claim that trial counsel was ineffective for not presenting expert forensic testimony to challenge the credibility of the prosecution's sole eyewitness. This failure is not a reasonable strategic choice when counsel neglects to investigate readily available extra-record evidence that directly contradicts the witness's account of the crime.
Facts:
- On September 25, 1989, Christopher Williams and others allegedly planned to rob Otis Reynolds, Gavin Anderson, and Kevin Anderson during a sham gun sale.
- The Commonwealth's key witness and alleged accomplice, James White, testified that during the robbery, Williams took one of the victims away and shot him.
- White then testified that he observed Williams interrogate and shoot a second victim inside a stolen van.
- According to White, Williams and co-defendant Rick Bennett then threw or pushed this victim's body out of the moving van onto the street.
- White claimed he then heard two more gunshots, after which the third victim's body was also thrown from the moving van.
- The bodies of the three victims were later found in separate locations.
- Medical examinations of the victims revealed that none of them had any scrapes, bruises, abrasions, or other non-gunshot injuries on their bodies.
Procedural Posture:
- A jury in the Philadelphia County Court of Common Pleas convicted Christopher Williams of three counts of first-degree murder, and he was sentenced to death.
- After trial counsel filed a post-sentence motion, new counsel (Attorney Seay) was appointed and filed an additional post-sentence motion, which the trial court denied.
- On direct appeal, the Supreme Court of Pennsylvania removed Attorney Seay and appointed new appellate counsel (Attorney Rudenstein).
- The Supreme Court of Pennsylvania affirmed Williams' judgment of sentence on direct appeal.
- Williams filed a timely Post Conviction Relief Act (PCRA) petition in the trial court, which was mostly denied but resulted in an order for a new trial on a separate ground.
- The Commonwealth appealed the new trial order to the Supreme Court of Pennsylvania, which vacated the conviction on one count but reversed the grant of a new trial, remanding the case to the PCRA court for further proceedings on the layered ineffectiveness claims.
- On remand, the PCRA court held an evidentiary hearing and again granted Williams a new trial based on ineffective assistance of trial and appellate counsel.
- The Commonwealth appealed that order to the Supreme Court of Pennsylvania, which is the subject of the present opinion.
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Issue:
Does appellate counsel's failure to raise a meritorious claim of trial counsel's ineffectiveness—specifically, trial counsel's failure to present expert forensic testimony that contradicts the key prosecution witness's account—constitute ineffective assistance of counsel warranting a new trial?
Opinions:
Majority - Justice Donohue
Yes. Appellate counsel was ineffective for failing to raise a meritorious claim of trial counsel's ineffectiveness, which warrants a new trial. The underlying claim against trial counsel has arguable merit because expert testimony on blood flow patterns and gunshot wounds, which was available at the time of trial, would have directly contradicted the Commonwealth's sole eyewitness, James White. Trial counsel had no reasonable strategic basis for this omission, admitting he 'didn't even give it a thought' to consulting an expert and failed to cross-examine the Commonwealth's experts on these critical inconsistencies. Williams was prejudiced because White's credibility was the linchpin of the prosecution's case, and this unpresented forensic evidence would have created a reasonable probability of a different outcome. Consequently, appellate counsel's failure to raise this strong, extra-record claim on direct appeal was not a reasonable 'winnowing' strategy and constituted ineffective assistance.
Concurring - Chief Justice Saylor
Yes. While agreeing that Williams is entitled to a new trial, the grant of relief is better justified by appellate counsel's failure to challenge the trial judge's improper conduct. The trial judge committed a clear abuse of discretion by repeatedly preventing defense counsel from cross-examining the medical experts about the lack of non-gunshot injuries on the victims, a key impeachment point against the Commonwealth's witness. The judge's actions, including denigrating the defense's line of questioning as 'silly' and 'nonsensical,' amounted to an error of 'essentially structural magnitude.' Appellate counsel's failure to raise this patently obvious and prejudicial trial court error was deficient performance warranting a new trial, a more compelling basis than the failure to adduce blood-spatter evidence.
Concurring - Justice Wecht
Yes. While joining the majority opinion, it is important to note that the majority improperly dismisses the PCRA testimony of Dr. Charles Wetli regarding the lack of abrasions and scrapes on the victims' bodies. The PCRA court found Dr. Wetli's testimony credible, and an appellate court is bound by that credibility determination when it is supported by the record. The majority oversteps its appellate authority by substituting its own judgment on the persuasiveness of the testimony and speculating on its admissibility. Dr. Wetli's testimony was a valid component of the PCRA court's finding that trial counsel was ineffective for failing to investigate and consult with any forensic experts, and it should not have been rejected.
Analysis:
This decision reaffirms the critical nature of counsel's duty to investigate, extending it beyond mere record review to a proactive duty to seek out scientific evidence that can challenge a prosecution's narrative. It clarifies that when a case hinges on a single, highly impeachable witness, the failure to present available forensic evidence that contradicts that witness's story is highly likely to be found prejudicial. The ruling also scrutinizes appellate strategy, establishing that the 'winnowing' of claims is only reasonable if based on a thorough investigation of all potential issues, including extra-record ones. The case serves as a powerful precedent for granting new trials where counsel's pre-trial preparation, not just courtroom performance, is fundamentally deficient.
