Commonwealth of Pennsylvania v. Stephen Rex Edmiston

Summary

The Supreme Court of Pennsylvania affirmed the denial of relief on Stephen Rex Edmiston's second and supplemental PCRA petitions, holding every claim untimely under the jurisdictional time bar of 42 Pa.C.S. § 9545(b): trial counsel knew of the Coroner's autopsy photographs at trial, the Kruis-map and Brown-statement predicates could have been developed earlier with due diligence, and the 2009 NAS Report merely compiled hair-analysis criticisms that had been in the public domain since as early as 1974. The Court also affirmed denial of post-conviction DNA testing but on the alternative ground that the motion, first made in late 2008 by a continuously represented capital inmate who had declined further testing at trial and sought testing only as his serial PCRA litigation neared its end, was not made 'in a timely manner' for actual innocence under 42 Pa.C.S. § 9543.1(d)(1)(iii) but to delay execution. The Court further found no abuse of discretion in denying post-conviction discovery aimed at the merits of untimely claims. Justice Todd filed a concurrence: she would have found the NAS Report claim timely because its unsourced conclusions were novel, but would still deny relief as impeachment evidence unlikely to change the verdict; Justice Saylor joined the majority except as to the DNA testing ruling, concurring in the result.