Com. v. Leslie, C., 923 WDA 2016

Appellant Casey Lynn Leslie pled guilty to first-degree felony robbery on May 9, 2013; a firearm was used and the Commonwealth sought a five-year mandatory minimum.
Sentenced June 21, 2013 to 5–10 years; no post-sentence motions or direct appeal were filed, so judgment became final on July 21, 2013.
Appellant filed a pro se motion to correct an illegal sentence on November 2, 2015, which the court treated as a PCRA petition; counsel was later appointed and an amended PCRA petition was filed December 14, 2015.
The PCRA court issued notice of intent to dismiss and later denied the petition on June 13, 2016 as untimely; no Pa.R.A.P. 1925(b) statement was filed.
Appellant relied on Alleyne v. United States and argued his petition met the PCRA time‑bar exception and was filed within 60 days of being notified of Alleyne.
The Superior Court affirmed, concluding the petition was untimely and no statutory exception applied (Alleyne had not been held retroactive and was not a newly discoverable fact that tolled the 60‑day period).

Issue	Appellant's Argument	Commonwealth's Argument	Held
Whether the PCRA petition was timely under PCRA exceptions	Leslie argued Alleyne created a new constitutional right triggering §9545(b)(1)(iii) or constituted a newly discovered fact under §9545(b)(1)(ii), and his pro se filing was within 60 days of learning of Alleyne	The Commonwealth argued the petition was untimely; Alleyne has not been held retroactive and does not save the untimely petition; 60‑day clock runs from Alleyne decision date	Court held petition untimely; no jurisdiction because no applicable §9545(b) exception; Alleyne not shown to be retroactive and 60‑day period had expired

Commonwealth v. Anderson, 995 A.2d 1184 (Pa. Super. 2010) (standard of review for PCRA denial)
Commonwealth v. Chester, 895 A.2d 520 (Pa. 2006) (PCRA time limits are jurisdictional)
Commonwealth v. Lambert, 884 A.2d 848 (Pa. 2005) (jurisdictional consequences of untimely PCRA petitions)
Commonwealth v. Miller, 102 A.3d 988 (Pa. Super. 2014) (Alleyne claim cannot overcome PCRA time bar absent retroactivity)
Commonwealth v. Watts, 23 A.3d 980 (Pa. 2011) (decisional law is not a new "fact" under §9545(b)(1)(ii))
Commonwealth v. Boyd, 923 A.2d 513 (Pa. Super. 2007) (60‑day filing period runs from underlying judicial decision date)
Commonwealth v. Brandon, 51 A.3d 231 (Pa. Super. 2012) (prisoners are not entitled to be notified of changes in case law)
Commonwealth v. Baldwin, 789 A.2d 728 (Pa. Super. 2001) (similar principle that courts and correctional systems need not inform prisoners of new decisions)
Alleyne v. United States, 570 U.S. 99 (U.S. 2013) (held that facts increasing mandatory minimums must be found by jury)