Com. v. Goodridge, S.
498 MDA 2016
| Pa. Super. Ct. | Jan 19, 2017Background
- In December 2013 Goodridge struck and then stabbed a bar patron; the victim survived. Goodridge was charged with multiple offenses.
- On July 30, 2014 Goodridge pled guilty to one count of aggravated assault (18 Pa.C.S. § 2702(a)(1)); remaining charges were withdrawn.
- On October 21, 2014 the trial court sentenced Goodridge to 90–180 months’ incarceration plus two years’ consecutive probation and restitution.
- Goodridge did not file a direct appeal; he filed a pro se PCRA petition on July 31, 2015. Counsel was appointed, filed a Turner/Finley no‑merit letter and petition to withdraw, and the PCRA court granted withdrawal and dismissed the petition on March 2, 2016.
- Goodridge appealed pro se, raising multiple ineffective‑assistance claims, claims that the plea was unlawfully induced and that the Commonwealth breached the plea, and contending the conduct did not constitute aggravated assault.
- The Superior Court affirmed, adopting the PCRA court’s detailed opinion finding the plea voluntary, the ineffectiveness allegations undeveloped/meritless, and most issues waived by the guilty plea.
Issues
| Issue | Goodridge’s Argument | Commonwealth / Trial Court Argument | Held |
|---|---|---|---|
| Ineffective assistance (general; due process & Sixth Amendment) | Counsel failed to protect federal and state constitutional rights and zealously represent him. | Claims are bald/boilerplate, not developed; record shows knowing, voluntary plea and no factual support for ineffective assistance. | Denied — claims waived or meritless. |
| Failure to challenge sufficiency of evidence / sentence | Counsel should have contested that the conduct did not rise to aggravated assault. | Sufficiency claims waived by guilty plea; plea colloquy shows Goodridge admitted elements. | Denied — waived and contradicted by record. |
| Unlawfully induced guilty plea / false sentencing information | Counsel gave false information about sentencing, inducing the plea. | Plea colloquy (written and oral) informed Goodridge of elements, ranges, and that no other promises were made; he knowingly accepted plea. | Denied — plea voluntary and not unlawfully induced. |
| Failure to file post‑sentence appeal | Counsel abandoned him by not filing post‑sentence appeals. | No allegation or proof Goodridge requested counsel to file an appeal; petitioner must prove he asked. | Denied — no evidence he requested an appeal. |
Key Cases Cited
- Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988) (procedures for counsel withdrawing after concluding PCRA petition is meritless)
- Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (procedures for no‑merit letter and counsel withdrawal)
- Commonwealth v. Chmiel, 30 A.3d 1111 (Pa. 2011) (‘‘boilerplate’’/bald assertions cannot sustain ineffective assistance claim)
- Commonwealth v. Johnson, 985 A.2d 915 (Pa. 2009) (issues waived if not developed with citation to authority)
- Commonwealth v. Albrecht, 720 A.2d 693 (Pa. 1998) (PCRA court duties when counsel is appointed and files no‑merit letter)
- Commonwealth v. Langston, 904 A.2d 917 (Pa. Super. 2006) (guilty plea waives challenge to sufficiency of evidence)
- Commonwealth v. Williams, 660 A.2d 614 (Pa. Super. 1995) (same)
- Commonwealth v. Harvey, 812 A.2d 119 (Pa. 2002) (bald allegations of additional investigation benefiting defendant insufficient)
- Commonwealth v. Maynard, 900 A.2d 395 (Pa. Super. 2006) (counsel may be ineffective for failing to file direct appeal where defendant requested one)
- Commonwealth v. Rarmon, 738 A.2d 1023 (Pa. Super. 1999) (burden on petitioner to prove he requested counsel file an appeal)
