Com. v. Fields, R.
22 EDA 2016
| Pa. Super. Ct. | Oct 19, 2016Background
- Rudolph Fields committed violent sexual and related offenses in December 2002 after earlier convictions; he pleaded guilty on April 19, 2005 and received an aggregate sentence that was later reinstated on March 20, 2015.
- Fields sought to withdraw his guilty plea after resentencing and contended the plea was not knowing, intelligent, and voluntary.
- Counsel filed an Anders/McClendon brief seeking permission to withdraw, asserting no non-frivolous issues for appeal.
- The Superior Court reviewed the plea colloquy and the record, examined counsel’s Anders compliance, and independently assessed arguable merit.
- The court concluded the plea colloquy covered required topics (nature of charges, factual basis, rights waived, sentencing exposure, etc.), found no manifest injustice, and affirmed the judgment of sentence while granting counsel’s petition to withdraw.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Fields’ guilty plea was knowing, intelligent, and voluntary | Fields: plea involuntary; seeks withdrawal nunc pro tunc | Commonwealth: plea was voluntary; colloquy adequate; no manifest injustice | Court: Plea was voluntary based on comprehensive colloquy; no manifest injustice; claim fails |
| Whether counsel complied with Anders/McClendon requirements for withdrawal | Fields: (implicitly) counsel’s brief insufficient to raise plea-voluntariness claim | Counsel/Appellate: Anders brief satisfied Santiago factors and advised defendant of rights | Court: Counsel complied with Anders and Santiago; permitted counsel to withdraw |
| Standard for post-sentence plea withdrawal and application here | Fields: argues relief from sentence via plea withdrawal | Commonwealth: post-sentence withdrawal requires showing of manifest injustice (involuntariness) | Court: Applied manifest injustice standard; record shows voluntariness so withdrawal denied |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (U.S. 1967) (procedural requirements when appointed counsel seeks to withdraw)
- McClendon v. Commonwealth, 434 A.2d 1185 (Pa. 1981) (Pa. counterpart on counsel withdrawal procedure)
- Commonwealth v. Santiago, 978 A.2d 349 (Pa. 2009) (clarifies Anders requirements in Pennsylvania)
- Commonwealth v. Muntz, 630 A.2d 51 (Pa. Super. 1993) (distinguishes pre- and post-sentence plea-withdrawal standards)
- Commonwealth v. Muhammad, 794 A.2d 378 (Pa. Super. 2002) (post-sentence withdrawal requires showing plea was involuntary, unknowing, or unintelligent)