Pennsylvania v. Spotz

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In consolidated appeals, the issue presented for the Pennsylvania Supreme Court’s review centered on whether the invocation of the United States Supreme Court’s decisions in Johnson v. United States, 135 S.Ct. 2551 (2015), and Welch v. United States, 136 S.Ct. 1257 (2016), satisfied the newly-recognized constitutional right exception to the time limit prescribed by the Pennsylvania Post Conviction Relief Act (“PCRA”). The Pennsylvania Court held that neither “Johnson” nor “Welch” created a constitutional right that applied retroactively to Mark Spotz. In 1995, Spotz embarked upon a three-day homicide spree through York, Schuylkill, Cumberland, and Clearfield Counties. Spotz killed four people, one of whom was his own brother. In 1996, Spotz was convicted of first-degree murder and sentenced to death in York, Schuylkill, and Cumberland Counties. In Clearfield County, Spotz was convicted of, inter alia, voluntary manslaughter for the killing of his brother, and received a lengthy prison sentence. The cases at issue here concerned Spotz’ death sentences in Cumberland and Schuylkill Counties. In each case, Spotz filed facially untimely petitions for collateral relief, in which he maintained that “Johnson” and “Welch” sufficed to satisfy the newly-recognized constitutional right exception. The Pennsylvania Court determined the timeliness exception did not apply, and affirmed the PCRA court’s conclusion that Spotz’ petitions were untimely, rendering Pennsylvania courts without jurisdiction to provide relief. View "Pennsylvania v. Spotz" on Justia Law