Com. v. McLaughlin, M., 2422 EDA 2016

Appellant Melvin McLaughlin shot victim Rasheed Teel multiple times in broad daylight; Teel survived and identified McLaughlin at trial. McLaughlin then elected to enter an open guilty plea during trial.
The court conducted a detailed on-the-record plea colloquy; McLaughlin acknowledged the plea was open, that no promises had been made about sentence length, and that he understood rights waived and limited appeal grounds.
At sentencing the court imposed an aggregate term of 20 to 45 years' imprisonment (concurrent and consecutive components across three dockets).
McLaughlin filed a pro se PCRA petition alleging trial/plea counsel were ineffective by promising a maximum aggregate sentence of ~13 years and thus inducing an involuntary plea; he later filed an amended PCRA with affidavits from third parties.
The PCRA court dismissed the petition without an evidentiary hearing, finding the plea colloquy and written plea forms established the plea was knowing, voluntary, and intelligent; the court also found McLaughlin’s appellate statement vague and waived issues.
The Superior Court affirmed, agreeing that (1) McLaughlin waived his challenge by filing a conclusory Rule 1925(b) statement and (2) even on the merits the ineffective-assistance claim lacked arguable merit because the record (colloquy and written waivers) showed a voluntary open plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plea counsel was ineffective for allegedly promising a 13-year aggregate sentence, rendering the guilty plea involuntary	McLaughlin: counsel told him the court would impose max ~13 years, so plea was induced and unknowing	Commonwealth: plea was open; court warned no promise; colloquy and written waivers show plea was knowing and voluntary	Denied — claim lacks arguable merit; record shows plea was knowingly, voluntarily entered
Whether issue is preserved for appellate review (Rule 1925(b) statement)	McLaughlin: appealed dismissal and requested relief to withdraw plea or an evidentiary hearing	Commonwealth/trial court: McLaughlin’s concise statement was conclusory and insufficient to identify errors	Denied — Superior Court agrees issue was waived for being too vague; alternative merits disposition also rejected

Strickland v. Washington, 466 U.S. 668 (establishes two-prong ineffective assistance standard) (federal precedent relied on for prejudice/deficient performance framework)
Commonwealth v. Turetsky, 925 A.2d 876 (Pa. Super. 2007) (PCRA ineffective-assistance elements and burden on petitioner)
Commonwealth v. Pollard, 832 A.2d 517 (Pa. Super. 2003) (mere disappointment in sentence does not render plea involuntary)
Commonwealth v. Yager, 685 A.2d 1000 (Pa. Super. 1996) (ineffectiveness claims tied to guilty pleas require causal nexus to unknowing or involuntary plea)
Commonwealth v. Lemon, 804 A.2d 34 (Pa. Super. 2002) (Rule 1925(b) concise statement must identify issues with sufficient detail; vague statements result in waiver)
Commonwealth v. Clark, 961 A.2d 80 (Pa. 2008) (PCRA court may deny evidentiary hearing if petition fails to raise genuine issue of material fact)
Commonwealth v. Burkett, 5 A.3d 1260 (Pa. Super. 2010) (petitioner bears burden to prove all prongs of ineffectiveness test)
Commonwealth v. Fluharty, 632 A.2d 312 (Pa. Super. 1993) (totality of circumstances governing validity of guilty plea)