Commonwealth v. Hamilton

Reversing the denial of PCRA relief and remanding for a new trial, the Superior Court held that trial counsel was ineffective for failing to oppose the Commonwealth’s joinder motion. The Court reiterated that joinder is improper where evidence of one offense would not be cross-admissible in a separate trial for the other, and clarified that under Pa.R.E. 404(b), evidence of an uncharged or separately charged crime is not made admissible simply because it provides background or chronological context; it must go to a recognized non-propensity purpose such as motive, identity, or common scheme. The opinion reinforces that judicial economy cannot justify exposing a defendant to a heightened probability of prejudice, and that counsel’s strategic explanations for acquiescing to joinder lacked a reasonable basis where the joined evidence would have been independently inadmissible.