Com. v. Hoye, N., 911 WDA 2024

Nathan Hoye, an HIV-positive inmate, pleaded guilty in 2019 to aggravated assault and related offenses after throwing urine on a corrections officer while incarcerated.
After multiple appeals and remands for resentencing, his conviction and sentence were ultimately affirmed by the Superior Court on November 1, 2023.
Hoye filed a timely pro se PCRA (Post Conviction Relief Act) petition arguing various grounds, including ineffective assistance, lack of evidence, and double jeopardy concerns.
Appointed PCRA counsel moved to withdraw with a Turner/Finley no-merit letter; the PCRA court issued notice of intent to dismiss, citing lack of jurisdiction over factual plea challenges and previously litigated issues.
Hoye's concise statement on appeal was deemed too vague to identify specific errors, leading the PCRA court to find all appellate issues waived.
On appeal, Hoye’s pro se briefs were found to violate procedural rules, further justifying dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preservation of Issues	Hoye raised various claims, including mental health and double jeopardy, in a vague concise statement.	State contended statement was too vague for review.	Issues waived for lack of specificity in concise statement.
Procedural Defects in Briefing	Hoye filed handwritten, noncompliant appellate briefs.	Briefs failed to conform to appellate rules.	Dismissal justified by briefing defects.
Jurisdiction Over Plea Challenges	Hoye sought to challenge the factual basis of his guilty plea.	Argues PCRA court lacks jurisdiction.	PCRA court lacked jurisdiction to revisit factual plea issues.
Previously Litigated Claims	Hoye attempted to relitigate sentencing and double jeopardy arguments.	Issues already addressed in prior appeals.	Claims were previously litigated and lacked merit.

Commonwealth v. Lord, 719 A.2d 306 (Pa. 1998) (failure to specify issues in a Rule 1925(b) statement results in waiver of those issues on appeal)
Commonwealth v. Blakeney, 108 A.3d 739 (Pa. 2014) (pro se litigants are granted no special advantages, though their filings may be liberally construed)