Com. v. Medelo, E., Com. v. Medelo, E. No. 3335 EDA 2016

Between May and June 2012 Medelo and an accomplice committed multiple burglaries of convenience stores/gas stations by smashing windows and stealing cigarettes; they were caught June 11, 2012.
Medelo entered open nolo contendere pleas to multiple burglary counts and conspiracy; his presentence report showed numerous prior burglaries and a heroin addiction; sentence imposed was 14–28 years with RRRI eligibility.
Trial counsel was replaced before sentencing; successor counsel (Banta) initially filed to withdraw Medelo’s pleas but withdrew that motion and proceeded to sentencing.
Medelo later filed a PCRA petition alleging ineffective assistance because counsel failed to communicate a Commonwealth global plea offer of a 7‑year minimum before it expired.
At the PCRA evidentiary hearing counsel testified he had discussed multiple offers, including the 7‑year aggregate minimum with Medelo prior to the acceptance deadline, and Medelo rejected the offer; the court found counsel credible.
The PCRA court denied relief; the Superior Court affirmed, holding counsel was not ineffective for failing to convey the offer because counsel did convey it and Medelo refused it.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for failing to communicate a 7‑year global plea offer before it expired	Medelo: counsel did not inform him of the Commonwealth’s 7‑year offer in time, so he lost the chance to accept a lesser sentence	Commonwealth/PCRA court: trial counsel testified he informed Medelo of the 7‑year offer before the deadline and Medelo rejected it	Denied — court credited counsel’s testimony; no deficient performance or prejudice shown

Strickland v. Washington, 466 U.S. 668 (1984) (establishes two‑prong ineffective assistance standard requiring deficient performance and prejudice)
Commonwealth v. Pierce, 527 A.2d 973 (Pa. 1987) (breaks performance inquiry into two parts and applies tripartite test)
Commonwealth v. Koehler, 36 A.3d 121 (Pa. 2012) (discusses ineffective assistance and prejudice standard under Pennsylvania law)
Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988) (counsel withdrawal/no‑merit letter procedures)
Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (en banc) (procedures for appellate counsel filing no‑merit brief and withdrawing)
Commonwealth v. Muzzy, 141 A.3d 509 (Pa. Super. 2016) (clarifies counsel’s duties when moving to withdraw under Turner/Finley)
Commonwealth v. Widgins, 29 A.3d 816 (Pa. Super. 2011) (requires independent court review when counsel files Turner/Finley letter)
Commonwealth v. Callahan, 101 A.3d 118 (Pa. Super. 2014) (treats subsequent PCRA as first petition for timeliness when direct appeal rights are reinstated nunc pro tunc)
Commonwealth v. Wilson, 824 A.2d 331 (Pa. Super. 2003) (standard of review for PCRA dismissals)