Com. v. Lehman, M., 122 A.3d 1131

Lehman was 14 when charged with murder and related offenses for the 1988 Kwame Beatty killing and tried as an adult in 1990.
He was convicted of first-degree murder and sentenced to life without parole, plus concurrent/ consecutive terms for other offenses.
Direct appeal resolved in 1991 by this Court, affirming the judgment of sentence.
First PCRA petition filed October 8, 1998; denied May 26, 1999; affirmed on appeal in 2000.
Second PCRA petition filed July 1, 2010; dismissed August 26, 2010; affirmed by this Court in 2011; Supreme Court denied review in 2011.
Third PCRA petition filed August 21, 2012; dismissed November 20, 2013; amended to Miller v. Alabama claim; stayed pending Cunningham; Cunningham held Miller not retroactive; petition dismissed as untimely.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is Miller retroactive after Cunningham on PCRA review?	Lehman argues Miller applies retroactively to permit relief.	Commonwealth contends Cunningham forecloses retroactive relief for Miller.	No retroactive relief; petition untimely under 9545.
Does Miller relief require a new sentencing hearing under state or federal standards?	Lehman seeks a new sentencing hearing based on Miller/Cunningham.	Commonwealth maintains no entitlement to a new sentencing hearing under current law.	Not warranted; untimely and without retroactive authority.
Was Lehman's petition timely under 42 Pa.C.S. § 9545’s exceptions?	Lehman argues exceptions apply due to new retroactivity and Miller/Cunningham developments.	Commonwealth asserts no applicable exception; petition is facially untimely.	No exceptions apply; petition time-barred.

Miller v. Alabama, 132 S. Ct. 2455 (U.S. Supreme Court 2012) (mandatory life without parole for juveniles violates Eighth Amendment in some contexts)
Commonwealth v. Cunningham, 81 A.3d 1 (Pa. 2013) (Miller retroactivity not applied retroactively in collateral review)