Curtis Williams v. J. Rivello, et al.

CourtDistrict Court, E.D. Pennsylvania
DecidedAugust 5, 2024
Docket2:23-cv-04033
StatusUnknown

This text of Curtis Williams v. J. Rivello, et al. (Curtis Williams v. J. Rivello, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Curtis Williams v. J. Rivello, et al., (E.D. Pa. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

____________________________________ : CURTIS WILLIAMS : : v. : NO. 23-CV-4033 : J. RIVELLO, et al. : ____________________________________:

REPORT AND RECOMMENDATION

SCOTT W. REID DATE: August 5, 2024 UNITED STATES MAGISTRATE JUDGE

This is a pro se petition for writ of habeas corpus filed pursuant to 28 U.S.C. §2254 by Curtis Williams, who is currently incarcerated at SCI Huntingdon, in Huntingdon, Pennsylvania. For the reasons that follow, I recommend that the petition be denied. I. Factual and Procedural Background On June 22, 2017, following a jury trial in the Court of Common Pleas for Philadelphia County, Williams was convicted of first-degree murder and related firearms offenses. Petition at ¶¶ 1, 2, 5. He was sentenced on the same day to a mandatory sentence of life imprisonment. Id. at ¶¶2, 3. The facts underlying Williams’ conviction were set forth in the Pennsylvania Courts as follows: On December 20, 2014, Williams shot and killed the decedent, Robert Andrews, in front of the decedent’s home at 1600 Paul Street in Philadelphia. Michael Rich, the decedent’s cousin, heard numerous gunshots, looked out of the window of the home located at 1600 Paul Street and observed Williams running with a silver and black gun. He knew Williams from seeing him around the neighborhood for the previous three months. Williams also had a distinctive limp and was wearing a black sweatshirt with the insignia “Columbia” on it, which Mr. Rich had seen Williams wearing earlier in the day. Rich went outside and found the decedent on the sidewalk, shot multiple times. Approximately two weeks before the decedent’s murder, Rich saw Williams running past his house with his distinctive limp while holding a silver and black gun.

Blanche Jackson, also a cousin of the decedent, was present at the Paul Street home when the murder occurred. She heard a gate rattle, followed by the decedent saying “Oh, shit,” followed by numerous gunshots.

Jackson looked out the bathroom window and saw Williams standing under a streetlight, placing a big silver gun into his waistband before running through the alleyway. Jackson knew the Defendant from seeing him around the neighborhood.

The day after the murder, Jackson was approached by “G” who she had seen hanging with Williams. “G” told Jackson that she would be next if she talked to the cops.

Daryl Harrison Locke told detectives that he had known Williams for over five years. Two weeks before the murder, Williams showed Locke a silver colored .40 caliber Smith & Wesson with black grips.

Locke recanted at trial, testifying that the detectives told him what to say in his statement. It should be noted that Locke was stabbed in prison after his statement was passed around the block in the prison prior to him testifying.

Finally, Police Officer Lally testified that on December 27, 2014, he arrested Williams and recovered from his waistband a chrome and black .40 caliber Smith & Wesson firearm.

Commonwealth v. Williams, 293 A.3d 640 (Table), 2023 WL 2231257 at *1 (Pa. Super. Feb. 27, 2023). (Repetitions of Williams’ name removed from brackets for ease in reading). After his conviction, Williams’ counsel filed a timely appeal, claiming in his Concise Statement under Pennsylvania Rule of Appeal 1925(b) that the verdict at trial was based on insufficient evidence, and against the weight of the evidence; and that the trial court erred in denying Williams’ motion to suppress the firearm recovered from him on the basis that he was arrested without probable cause. Commonwealth v. Williams, CP-51-CR-0005345-2015 (C.C.P. Phila. Mar. 26, 2018), attached to Commonwealth’s Response as Exhibit B-1, at 2. However, Williams was subsequently granted leave to dismiss counsel and proceed pro se. Id. Ultimately, the only issues he raised in his direct appeal were (1) that the trial court erred in denying him an evidentiary hearing on the claim that Detective James Pittss, one of the detectives who interrogated Daryl Harrison-Locke, was known to fabricate evidence and suborn

perjury; and (2) somewhat obscurely, that the Commonwealth had waived its right to try him for first-degree murder by declining to seek the death penalty. Commonwealth v. Williams, 3690 EDA 2017, 2019 WL 3800286 (Pa. Super. Aug. 13, 2019) at *1. The Pennsylvania Superior Court denied Williams’ appeal on August 13, 2019. Id. Williams did not seek review in the Pennsylvania Supreme Court. Williams then filed a timely pro se petition under Pennsylvania’s Post Conviction Relief Act, (“PCRA”), 42 Pa. C.S. §9541, et seq. 2023 WL 2231257 at *2. In it, he argued that trial counsel was ineffective for (a) failing to object to vouching in the prosecutor’s closing argument; (b) failing to raise the claim that he could not be tried for first-degree murder because the Commonwealth did not seek the death penalty; and (c) not investigating Detective Pittss’ former

misconduct. Id. PCRA counsel was appointed, but moved on March 18, 2021, to withdraw under Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988), having concluded that there was no merit to Williams’ claims. Id. Williams was granted two extensions in which to respond to the PCRA court’s notice of its intent to dismiss the petition under Pa. R. Crim. 907, but his motion for a third extension was denied. Id. He did not file a response. On August 26, 2021, the PCRA court formally dismissed Williams’ petition without a hearing. Id. Williams appealed the dismissal of his PCRA petition to the Pennsylvania Superior Court. Id. In his appeal, he argued that “PCRA counsel’s independent review of the record was insufficient to find meritorious issues to raise because he did not try to obtain the homicide file … in his case before he moved to withdraw.” Id. The Superior Court, however, affirmed the

dismissal of Williams’ PCRA petition on February 27, 2023. Id. at *5. On October 16, 2023, Williams filed the present petition for habeas corpus relief. In it, he raises the following claims: (1) the evidence in his case was insufficient to support his conviction; (2) counsel for the prosecution committed impermissible vouching in his closing argument; (3) trial counsel was ineffective in failing to object to the trial counsel’s vouching; (4) the prosecution violated Brady v. Maryland by concealing the fact that Detectives Pittss and Jenkins were on a “no-call list” because each of them had a history of misconduct; (5) trial counsel was ineffective for failing to enforce Williams’ “disclosure rights” under Brady; (6) the court wrongly instructed the jury in some respects and (7) counsel was ineffective in failing to object to the defective instructions.

II. Relevant Legal Standards A. Exhaustion and Procedural Default Before a federal court can consider the merits of a habeas claim, a petitioner must comply with the exhaustion requirement of 28 U.S.C. § 2254(b), giving “the state courts one full opportunity to resolve any constitutional issues by invoking one complete round of the State’s established appellate review process.” O’Sullivan v. Boerckel, 526 U.S. 838, 845 (1999). This requires the claim to have been presented at least to the Pennsylvania Superior Court. Lambert v. Blackwell, supra, at 387 F.3d 233-4. A petitioner’s failure to exhaust state remedies may be excused in limited circumstances on the ground that exhaustion would be futile. Lambert v. Blackwell, 134 F.3d 506

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Bluebook (online)
Curtis Williams v. J. Rivello, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/curtis-williams-v-j-rivello-et-al-paed-2024.