Com. v. McGrath, J., Com. v. McGrath, J. No. 1354 EDA 2016

McGrath entered open guilty pleas in 2011 to aggravated assault, related conspiracies, solicitation to murder, and witness intimidation based on a brutal 2010 beating and later recorded jail calls and threats.
Plea colloquies complied with Pa.R.Crim.P. 590; court advised McGrath of charges, factual basis, trial rights, presumption of innocence, and maximum aggregate exposure (100 years).
McGrath was sentenced to an aggregate 20–40 years’ imprisonment plus 10 years’ probation; post-sentence motions were denied and direct appeal affirmed in 2013.
McGrath filed a timely pro se PCRA petition in 2013, counsel was appointed, an amended PCRA petition was filed, and the PCRA court issued Pa.R.Crim.P. 907 notice of intent to dismiss.
McGrath claimed plea counsel was ineffective for allegedly advising him he would receive a 10-year sentence if he pleaded guilty, which he said induced an involuntary, unknowing plea; the PCRA court dismissed the petition without an evidentiary hearing.
On appeal, the Superior Court affirmed: it held the record (including the plea colloquy and prior appellate finding) established the plea was knowing, voluntary, and intelligent, and McGrath failed to show counsel caused an involuntary plea.

Issue	McGrath’s Argument	Commonwealth/PCRA Court’s Argument	Held
Whether PCRA court abused discretion by denying evidentiary hearing on plea-withdrawal claim	Counsel told him he would get 10 years if he pleaded, so his plea was involuntary; hearing needed to develop facts	Record shows plea colloquy and prior appellate decision establish voluntariness; claim is meritless, so no hearing required	Denied — no abuse; hearing not required because claim lacked merit
Whether plea counsel was ineffective for misadvising about sentence and inducing plea	Counsel’s advice caused an unknowing, involuntary plea — satisfies manifest injustice	Plea colloquy demonstrates McGrath knew charges, potential maximums, and rights; prior appellate decision found plea voluntary, so no ineffectiveness shown	Denied — ineffective-assistance claim fails (no arguable merit, no prejudice)

Commonwealth v. Willis, 68 A.3d 997 (Pa. Super. 2013) (PCRA relief available when counsel’s ineffectiveness causes involuntary plea)
Commonwealth v. Bedell, 954 A.2d 1209 (Pa. Super. 2008) (post-sentence plea withdrawal requires showing of manifest injustice)
Commonwealth v. Zeigler, 112 A.3d 656 (Pa. Super. 2015) (plea colloquy must cover specified subjects to ensure plea is knowing and voluntary)
Commonwealth v. Roney, 79 A.3d 595 (Pa. 2013) (standard for reviewing denial of evidentiary hearing on PCRA claims)