Pennsylvania v. Watts
Annotate this CaseAppellee Edward Watts was convicted of first-degree murder and numerous other offenses in 2001 and sentenced to life imprisonment. He filed a timely direct appeal, but the Superior Court dismissed it for failing to include a docketing statement. Defense counsel was directed to certify that he had notified Appellee of the dismissal, but he never filed the required certification saying that he did so. Throughout 2002 and 2003, Appellee sought status updates on his appeal. In August, 2003, the Superior Court advised Appellee that his appeal had been dismissed. Within days of receiving that notice, Appellee filed a pro se Post Conviction Relief Act (PCRA) petition, seeking reinstatement of his appellate rights. The PCRA Court dismissed his claim, but the Superior Court reversed that decision. The Supreme Court was not persuaded by Appellee’s argument that because he did not know (and had no way of knowing except through his attorney) that the appeal had been dismissed, he should be afforded an opportunity to have his petition heard. The Court reversed the Superior Court’s decision, finding Appellee’s petition was properly dismissed in the lower court for being untimely filed.
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