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Commonwealth v. Williams

Pennsylvania Superior Court

January 25, 2021

In Commonwealth v. Williams, the defendant filed a fourth PCRA petition, alleging the discovery of new evidence about a Commonwealth witness. The PCRA court dismissed the petition, determining it was time-barred. The Pennsylvania Superior Court reversed. Applying Commonwealth v. Small, 238 A.3d 1267 (Pa. 2020), the Court held that the witness’s testimony was critical to the Commonwealth’s case and provided a motive for the shooting that no other witness had offered. That witness’s credibility was especially relevant because two other Commonwealth eyewitnesses repudiated or substantially diluted their out-of-court identifications at trial.

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