Com. v. Jenkins, J., Com. v. Jenkins, J. No. 191 EDA 2016

James Jenkins pled nolo contendere to aggravated assault and possession of an instrument of crime on August 10, 2011; he received an agreed sentence of 6–20 years (aggravated assault) and 2–5 years concurrent (PIC).
At the plea hearing Jenkins disclosed a schizophrenia diagnosis and testified that his illness and medication did not impair his ability to enter the plea; defense counsel agreed Jenkins was competent and that medication did not interfere.
Jenkins did not file a direct appeal; he filed a timely pro se PCRA petition in April 2012 and later an amended PCRA petition with counsel raising ineffective-assistance claims and alleging his plea was unknowing/involuntary.
Alleged defects included: counsel coercion to accept the plea, failure to investigate or pursue motions (including a competency/psychiatric evaluation), and failure to withdraw the plea after Jenkins requested it.
The PCRA court issued a Rule 907 notice and dismissed the petition without an evidentiary hearing on December 18, 2015; Jenkins appealed. The Superior Court affirmed, finding the plea colloquy and record rebutted claims of incompetence/ coercion and that Jenkins’ post hoc assertions lacked corroboration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for inducing an unknowing/involuntary plea (including coercion and failure to seek psychiatric evaluation)	Jenkins: schizophrenia and counsel pressure rendered plea involuntary; counsel should have sought psychiatric evaluation and not coerced plea	Commonwealth/PCRA Ct.: Plea colloquy and counsel’s on-record statements show Jenkins understood proceedings; no evidence counsel acted outside reasonable professional judgment	Court held counsel was not ineffective; plea was voluntary and Jenkins’ own colloquy testimony defeats the claim
Whether counsel was ineffective for failing to withdraw the guilty plea after Jenkins requested withdrawal	Jenkins: he told trial counsel after sentencing to withdraw the plea and go to trial	Commonwealth/PCRA Ct.: Jenkins’ assertion is a bald, uncorroborated claim made months after sentencing; no record evidence supports request	Court held the unsupported after-the-fact claim insufficient to show counsel ineffective
Whether the PCRA court erred by denying an evidentiary hearing on Jenkins’ amended PCRA petition	Jenkins: factual disputes (competence, coercion, request to withdraw) warranted a hearing	Commonwealth/PCRA Ct.: Record and plea colloquy resolve the claims; issues are frivolous or without support, so no hearing required	Court held no error; evidentiary hearing not required because claims lacked merit or factual support

Commonwealth v. Battle, 883 A.2d 641 (Pa. Super. 2005) (standard of review for PCRA orders)
Commonwealth v. Hickman, 799 A.2d 136 (Pa. Super. 2002) (plea-stage ineffective-assistance standards and prejudice inquiry)
Commonwealth v. Kersteter, 877 A.2d 466 (Pa. Super. 2005) (withdrawing plea when ineffective assistance induced an involuntary plea)
Commonwealth v. Kimball, 724 A.2d 326 (Pa. 1999) (PCRA three-prong ineffectiveness test and prejudice requirement)
Commonwealth v. Meadows, 787 A.2d 312 (Pa. 2001) (petitioner must prove all prongs of ineffectiveness test)
Commonwealth v. Carter, 656 A.2d 463 (Pa. 1995) (presumption that trial counsel is effective)
Commonwealth v. Patterson, 143 A.3d 394 (Pa. Super. 2016) (standards on plea voluntariness and colloquy reliance)
Commonwealth v. Stork, 737 A.2d 789 (Pa. Super. 1999) (defendant bound by plea colloquy statements)
Nix v. Whiteside, 475 U.S. 157 (U.S. 1986) (definition of reasonable probability relevant to prejudice analysis)