Com. v. Huth, W.

CourtSuperior Court of Pennsylvania
DecidedApril 1, 2025
Docket1426 MDA 2024
StatusUnpublished

This text of Com. v. Huth, W. (Com. v. Huth, 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. Huth, W., (Pa. Ct. App. 2025).

Opinion

J-S10022-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : WILLIAM JOSEPH HUTH : : Appellant : No. 1426 MDA 2024

Appeal from the PCRA Order Entered September 12, 2024 In the Court of Common Pleas of Schuylkill County Criminal Division at No(s): CP-54-CR-0000321-2022

BEFORE: BOWES, J., OLSON, J., and SULLIVAN, J.

MEMORANDUM BY OLSON, J.: FILED: APRIL 1, 2025

Appellant, William Joseph Huth, appeals from the order entered on

September 12, 2024, which denied his petition filed under the Post Conviction

Relief Act (“PCRA”), 42 Pa.C.S.A. §§ 9541-9546. We affirm.

On September 14, 2023, Appellant proceeded to a non-jury trial and, at

the conclusion of the trial, the trial court found Appellant guilty of

strangulation, simple assault, and theft by unlawful taking.1 On October 24,

2023, the trial court sentenced Appellant to serve an aggregate term of 54 to

108 months in prison for his convictions. Appellant filed a timely notice of

appeal from his judgment of sentence. On March 11, 2024, however,

Appellant filed a praecipe to withdraw his direct appeal in this Court. See

Praecipe to Withdraw Appeal at 1553 MDA 2023, 3/11/24, at 1. ____________________________________________

1 18 Pa.C.S.A. §§ 2718(a)(1), 2701(a)(1), and 3921(a), respectively. J-S10022-25

On April 8, 2024, Appellant, through counsel, filed a timely, first PCRA

petition. Within this petition Appellant raised a number of claims, including

that his trial counsel (hereinafter “Trial Counsel”) was ineffective for failing to

“explain[] to [Appellant] [voir] dire.” See Appellant’s Brief in Support of PCRA

Petition, 8/5/24, at 2.

On July 22, 2024, the PCRA court held an evidentiary hearing on

Appellant’s petition, where both Appellant and Trial Counsel testified.

As the PCRA court explained, during the hearing:

Appellant testified that he was never informed as to how a jury is selected or how jury selection works at all. He testified that he had essentially “no clue” regarding jury selection. . . .

[Trial Counsel] testified that it was [Appellant’s] idea to pursue a non-jury trial; specifically, Appellant wanted a non-jury trial because he felt that jurors would hold his father’s bad reputation against him. [Trial Counsel] testified that he recalled discussing generally what happens at a trial, including picking a jury. In addition, Appellant and [Trial Counsel] had previously completed extensive guilty plea paperwork because [Appellant] had been ready to take a plea offer prior to withdrawing it and proceeding to the non-jury trial, which he did against [Trial Counsel’s] advice. [Trial Counsel] testified that as part of the guilty plea colloquy, he explained jury selection to Appellant. At the evidentiary hearing, on cross-examination regarding the guilty plea colloquy, Appellant stated “I guess it’s my fault for not reading it.”

PCRA Court Opinion, 9/12/24, at 3.

The trial court denied Appellant’s PCRA petition on September 12, 2024

and Appellant filed a timely notice of appeal. Appellant raises two claims on

appeal:

-2- J-S10022-25

[1.] Whether [Trial Counsel] was ineffective in his explanation of jury selection to [Appellant]?

[2.] Whether [the PCRA court] improperly decided the PCRA [petition] without consideration of the evidence presented?

Appellant’s Brief at 4.

“We review a ruling by the PCRA court to determine whether it is

supported by the record and is free of legal error. Our standard of review of

a PCRA court's legal conclusions is de novo.” Commonwealth v. Cousar,

154 A.3d 287, 296 (Pa. 2017) (citations omitted). However, we afford “great

deference” to the PCRA court’s credibility determinations. Commonwealth

v. Flor, 259 A.3d 891, 910-911 (Pa. 2021). As our Supreme Court has

explained:

We will not disturb the findings of the PCRA court if they are supported by the record, even where the record could support a contrary holding. [An appellate court’s] scope of review is limited to the findings of the PCRA court and the evidence on the record of the PCRA court's hearing, viewed in the light most favorable to the prevailing party.

Id. (quotation marks and citations omitted).

To be eligible for relief under the PCRA, the petitioner must plead and

prove by a preponderance of the evidence that his conviction or sentence

resulted from “one or more” of the seven, specifically enumerated

circumstances listed in 42 Pa.C.S.A. § 9543(a)(2). One of these statutorily

enumerated circumstances is the “[i]neffective assistance of counsel which, in

the circumstances of the particular case, so undermined the truth-determining

-3- J-S10022-25

process that no reliable adjudication of guilt or innocence could have taken

place.” 42 Pa.C.S.A. § 9543(a)(2)(ii).

Counsel is presumed to have been effective and “the burden of

demonstrating ineffectiveness rests on [A]ppellant.” Commonwealth v.

Rivera, 10 A.3d 1276, 1279 (Pa. Super. 2010). To satisfy this burden,

Appellant must plead and prove by a preponderance of the evidence that:

(1) his underlying claim is of arguable merit; (2) the particular course of conduct pursued by counsel did not have some reasonable basis designed to effectuate his interests; and, (3) but for counsel’s ineffectiveness, there is a reasonable probability that the outcome of the challenged proceedings would have been different.

Commonwealth v. Fulton, 830 A.2d 567, 572 (Pa. 2003). As this Court has

A claim has arguable merit where the factual averments, if accurate, could establish cause for relief. See Commonwealth v. Jones, 876 A.2d 380, 385 (Pa. 2005) (“if a petitioner raises allegations, which, even if accepted as true, do not establish the underlying claim . . . , he or she will have failed to establish the arguable merit prong related to the claim”). Whether the facts rise to the level of arguable merit is a legal determination.

The test for deciding whether counsel had a reasonable basis for his action or inaction is whether no competent counsel would have chosen that action or inaction, or, the alternative, not chosen, offered a significantly greater potential chance of success. Counsel’s decisions will be considered reasonable if they effectuated his client's interests. We do not employ a hindsight analysis in comparing trial counsel's actions with other efforts he may have taken.

Prejudice is established if there is a reasonable probability that, but for counsel’s errors, the result of the proceeding would have been different. A reasonable probability is a

-4- J-S10022-25

probability sufficient to undermine confidence in the outcome.

Commonwealth v. Stewart, 84 A.3d 701, 707 (Pa. Super. 2013) (some

quotation marks and citations omitted). “A failure to satisfy any prong of the

test for ineffectiveness will require rejection of the claim.” Id.

On appeal, Appellant claims that Trial Counsel was ineffective, as

counsel failed to properly explain jury selection to Appellant. The PCRA court

held an evidentiary hearing on this issue and determined that Trial Counsel,

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Related

Commonwealth v. Fulton
830 A.2d 567 (Supreme Court of Pennsylvania, 2003)
Commonwealth v. Jones
876 A.2d 380 (Supreme Court of Pennsylvania, 2005)
Commonwealth v. Rivera
10 A.3d 1276 (Superior Court of Pennsylvania, 2010)
Commonwealth v. Cousar, B., Aplt.
154 A.3d 287 (Supreme Court of Pennsylvania, 2017)
Commonwealth v. Stewart
84 A.3d 701 (Superior Court of Pennsylvania, 2013)
Com. v. Fletcher, A.
2023 Pa. Super. 270 (Superior Court of Pennsylvania, 2023)

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Com. v. Huth, W., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-huth-w-pasuperct-2025.