Narrative Opinion Summary
The case involves an appellant challenging the dismissal of his third Post Conviction Relief Act (PCRA) petition related to his 1988 first-degree murder conviction, for which he received a life sentence. This petition, filed in 2008, alleged racial discrimination in jury selection, invoking the Sixth, Eighth, and Fourteenth Amendments and corresponding state constitutional provisions. The appellant argued a violation based on a 1990 lecture by the Philadelphia District Attorney's Office, claiming it demonstrated a discriminatory policy against African-American jurors. The PCRA court dismissed the petition as untimely under 42 Pa.C.S.A. § 9545(b), as it was filed over seventeen years after the judgment became final. The Superior Court upheld this, emphasizing that PCRA time limits are jurisdictional. The appellant contended that the petition should be exempt due to new evidence of governmental misconduct, asserting the evidence was withheld until 2005. However, the court found the claims untimely, as the information was publicized earlier and no new facts were presented. The court also rejected assertions of government interference, affirming no concealment occurred. Ultimately, appellant's claims of racial discrimination were unsupported, leading to the dismissal being affirmed.
Legal Issues Addressed
Exceptions to PCRA Timeliness Requirements under 42 Pa.C.S.A. § 9545(b)(1)(ii)subscribe to see similar legal issues
Application: The court found that the appellant failed to prove government interference or unknown facts, which would exempt him from the one-year filing requirement.
Reasoning: Appellant's allegations were deemed unsupported and general, failing to prove government interference.
Jurisdictional Time Limits for PCRA Petitionssubscribe to see similar legal issues
Application: The court reaffirmed that Pennsylvania courts treat PCRA time limits as jurisdictional, barring further review if not met.
Reasoning: The Superior Court... concluded that the untimeliness of Green's claims barred further review, as Pennsylvania courts treat PCRA time limits as jurisdictional.
Newly-Discovered Facts Exception under 42 Pa.C.S.A. § 9545(b)(1)(ii)subscribe to see similar legal issues
Application: The court noted that the after-discovered facts exception pertains to new facts, not merely new sources for known facts, which the appellant did not meet.
Reasoning: Furthermore, the Court clarified that the after-discovered facts exception pertains to new facts, not merely new sources for known facts, indicating Marshall did not meet the requirements under Section 9545(b)(1)(ii).
PCRA Petition Timeliness under 42 Pa.C.S.A. § 9545(b)(1)subscribe to see similar legal issues
Application: The court held that the appellant's third PCRA petition was untimely as it was filed over seventeen years after the judgment became final.
Reasoning: Appellant's third PCRA petition is untimely, having been filed over seventeen years after his judgment became final on January 23, 1991, following the Supreme Court's refusal to hear his appeal.
Racial Discrimination in Jury Selection and Batson Claimssubscribe to see similar legal issues
Application: The court dismissed the appellant's claim of racial discrimination in jury selection, finding no substantive evidence linked to the Sagel and McMahon lectures or notes.
Reasoning: The Court has consistently rejected claims linking these lectures and notes to a discriminatory practice in jury selection, reaffirming past decisions where similar arguments were dismissed.