Com. v. Cook, W.

CourtSuperior Court of Pennsylvania
DecidedSeptember 10, 2024
Docket1206 EDA 2023
StatusUnpublished

This text of Com. v. Cook, W. (Com. v. Cook, W.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Com. v. Cook, W., (Pa. Ct. App. 2024).

Opinion

J-S98001-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : WESLEY COOK : : Appellant : No. 1206 EDA 2023

Appeal from the PCRA Order Entered March 31, 2023 In the Court of Common Pleas of Philadelphia County Criminal Division at No: CP-51-CR-0113571-1982

BEFORE: PANELLA, P.J.E., STABILE, J., and BENDER, P.J.E.

MEMORANDUM BY STABILE, J.: FILED SEPTEMBER 10, 2024

Petitioner, Wesley Cook (also known as Mumia Abu-Jamal), appeals an

order dismissing his petition for postconviction relief. 1 In 1982, following a

jury trial, Petitioner was found guilty of the first-degree murder of Officer

Daniel Faulkner. Petitioner was sentenced to death in 1983, but that sentence

was later vacated, and a term of life was imposed. Several successive

postconviction petitions were then filed in the years after the judgment of

sentence became final. In his most recent petition filed in 2021 (his sixth),

Petitioner claims that new evidence entitled him to a new trial. This was based

on the recent disclosure of a letter written by a witness to the lead prosecutor

asking for money owed to him, as well as notations by the prosecutor

____________________________________________

1 Petitioner’s claims are governed by the Post Conviction Relief Act (PCRA), 42

Pa.C.S.A. §§ 9541-9546. J-S98001-24

regarding the race of prospective jurors. The Court of Common Pleas of

Philadelphia County (PCRA court) dismissed the petition without a hearing.

Finding no basis to disturb that ruling, we affirm.

The underlying facts of the case have previously been summarized as

follows:

[A]t approximately 3:55 a.m. on December 9, 1981, Officer Faulkner made a routine car stop on Locust Street between Twelfth and Thirteenth Streets in Center City Philadelphia. The car was driven by the [Petitioner’s] brother, William Cook. After making the stop, Officer Faulkner called for assistance on his police radio, requesting a police wagon to transport a prisoner. While Faulkner was trying to handcuff Cook, [Petitioner] ran from across the street and shot the officer once in the back. Faulkner was able to fire one shot, which wounded [Petitioner], but after Faulkner had fallen to the ground [Petitioner] shot him four more times at close range, once through the center of the face. [Petitioner] was found slumped against the curb in front of Cook's car and taken into custody by police officers who arrived on the scene within thirty to forty-five seconds. The officers had been in the area and were turning onto Locust Street from Twelfth Street in response to Faulkner's radio request. They were flagged down by a cab driver [Robert Chobert,] who had witnessed the shooting while stopped at the intersection of Thirteenth and Locust. Two other pedestrians also witnessed the incident and identified [Petitioner] as the perpetrator, both at the scene and during the trial.

Commonwealth v. Abu-Jamal, 555 A.2d 846, 848 (Pa. 1989) (affirming

judgment of sentence on direct appeal).

Additionally, when Petitioner was apprehended at the scene of the

shooting, he was wearing a gun holster. A handgun sold to Petitioner, and

registered in his name, was laying on the ground a few inches away from him.

When Petitioner was transported to a hospital for the treatment of his gunshot

-2- J-S98001-24

wound, multiple witnesses testified at trial that they heard him admit to

shooting Officer Faulkner, and express his hope that he was dead. See N.T.

Trial, 6/24/1982, 28-30, 33, 113-16, 135-36.

The jury found Petitioner guilty, and he was sentenced to death. The

judgment of sentence was upheld on direct appeal in 1989. See Abu-Jamal,

555 A.2d at 848. Petitioner then filed PCRA petitions in 1995, 2001, 2003,

and 2009. The first petition was denied after the PCRA court held an

evidentiary hearing. The second, third, and fourth petitions were dismissed

as untimely. In each of these four proceedings, the appeal was immediately

heard by the Pennsylvania Supreme Court,2 and the denial of relief was upheld

in each instance. See Commonwealth v. Abu-Jamal, 720 A.2d 79 (Pa.

1998) (affirming denial of first PCRA petition); Commonwealth v. Abu-

Jamal, 833 A.2d 719 (Pa. 2003) (affirming denial of second PCRA petition);

Commonwealth v. Abu-Jamal, 941 A.2d 1263 (Pa. 2008) (affirming denial

of third PCRA petition); Commonwealth v. Abu-Jamal, 40 A.3d 1230 (Pa.

2012) (affirming denial of fourth PCRA petition).

After obtaining federal habeas corpus relief, Petitioner’s death penalty

was overturned, and he was resentenced in 2012 to a prison term of life

without parole. On appeal, Petitioner’s life sentence was affirmed by this

2 42 Pa.C.S.A. § 9711(h)(1) mandates that in cases where party has been sentenced to death, his claims “shall be subject to automatic review by the Supreme Court of Pennsylvania[.]”

-3- J-S98001-24

Court. See Commonwealth v. Abu-Jamal, 3059 EDA 2012, 2013 WL

11257188 (Pa. Super. filed July 9, 2013) (unpublished memorandum).

In 2016, Petitioner filed his fifth PCRA petition, this time claiming that

his appellate rights from the four earlier PCRA proceedings had to be

reinstated pursuant to the United States Supreme Court’s decision in

Williams v. Pennsylvania, 579 U.S. 1 (2016). In that case, the defendant

was found guilty of first-degree murder and sentenced to death. The

Honorable Ronald Castille was the District Attorney of Philadelphia at the time

of the trial, and he had authorized prosecutors to seek the death penalty.

The defendant in Williams filed a PCRA petition seeking a new penalty-

phase trial, and that request was granted by the PCRA court. The

Pennsylvania Supreme Court reviewed the ruling, and by the time the Court

heard the appeal, the Chief Justice was the Honorable Ronald Castille, who

refused to recuse himself from the case. Our Supreme Court reversed the

award of relief and reinstated the defendant’s death penalty. However, on

further review before the United States Supreme Court, it was found that

Justice Castille’s refusal to recuse despite his “significant, personal

involvement in a critical trial decision” had “presented an unconstitutional risk

of bias” in the PCRA proceedings. Williams, 579 U.S. at 11. Our Supreme

Court’s opinion was vacated, and the Court was directed to reconsider the

defendant’s appeal without Justice Castille’s participation. See id., at 17.

After the Williams opinion was issued, Petitioner relied on it to contend

that Justice Castille’s participation in the appellate review of his own cases

-4- J-S98001-24

constituted a similar constitutional violation. In 2018, the PCRA court directed

the Commonwealth to produce its entire case file from the trial, and 32 boxes

of records were submitted. On January 3, 2019, the Commonwealth disclosed

for the first time that it had discovered another six boxes of previously

undisclosed documents.

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Batson v. Kentucky
476 U.S. 79 (Supreme Court, 1986)
Commonwealth v. Abu-Jamal
833 A.2d 719 (Supreme Court of Pennsylvania, 2003)
Commonwealth v. Abu-Jamal
555 A.2d 846 (Supreme Court of Pennsylvania, 1989)
Commonwealth v. Hill
727 A.2d 578 (Superior Court of Pennsylvania, 1999)
Commonwealth v. Abu-Jamal
941 A.2d 1263 (Supreme Court of Pennsylvania, 2008)
Commonwealth v. Thomas
717 A.2d 468 (Supreme Court of Pennsylvania, 1998)
Commonwealth v. Daniels
963 A.2d 409 (Supreme Court of Pennsylvania, 2009)
Commonwealth v. Rico
711 A.2d 990 (Supreme Court of Pennsylvania, 1998)
Commonwealth v. D'Amato
856 A.2d 806 (Supreme Court of Pennsylvania, 2004)
Commonwealth v. Lark
746 A.2d 585 (Supreme Court of Pennsylvania, 2000)
Commonwealth v. Abu-Jamal
720 A.2d 79 (Supreme Court of Pennsylvania, 1998)
Commonwealth v. Abu-Jamal
40 A.3d 1230 (Supreme Court of Pennsylvania, 2012)
Commonwealth v. Hutchinson
25 A.3d 277 (Supreme Court of Pennsylvania, 2011)
Commonwealth v. Bennett
930 A.2d 1264 (Supreme Court of Pennsylvania, 2007)
Commonwealth v. Spence
627 A.2d 1176 (Supreme Court of Pennsylvania, 1993)
Commonwealth v. Dickerson
900 A.2d 407 (Superior Court of Pennsylvania, 2006)
Commonwealth v. Paddy
15 A.3d 431 (Supreme Court of Pennsylvania, 2011)
Williams v. Pennsylvania
579 U.S. 1 (Supreme Court, 2016)
Commonwealth v. Wholaver, E., Aplt.
177 A.3d 136 (Supreme Court of Pennsylvania, 2018)

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