Com. v. Miller, S., 2085 MDA 2016

Shannon Miller pleaded guilty in Lebanon County in a case involving heroin that led to a victim’s death and later filed a first PCRA petition challenging plea counsel’s effectiveness.
Miller alleged plea counsel was ineffective for failing to interview Earl Miller, failing to seek an interview with co-defendant Andrew Houck, and failing to communicate with her about discovery.
The PCRA court held an evidentiary hearing where plea counsel testified and was found credible; the court found counsel met with Miller eight times and discussed strategy and plea options.
The district attorney would not offer less than a 6–15 year term; counsel explained potential to reduce exposure if Miller testified against the co-defendant, but Miller refused to do so and refused to identify the drug source.
Miller signed a written guilty plea colloquy and the court found her plea was knowing, intelligent, and voluntary; counsel had delivered and reviewed the discovery packet with Miller in prison.
The PCRA court denied relief; Miller appealed and the Superior Court affirmed, adopting the PCRA court’s reasoning.

Issue	Miller's Argument	Commonwealth's Argument	Held
Whether plea counsel was ineffective for failing to interview Earl Miller	Counsel’s interview would have produced helpful evidence to challenge plea	Miller repeatedly told counsel she intended to plead guilty; no showing interview would have helped	Denied — no evidence interview would have aided Miller
Whether plea counsel was ineffective for not seeking interview with co-defendant Andrew Houck	Interview could have produced exculpatory or mitigating information	Miller refused offers (including testifying) that might produce a better plea; no proof Houck interview would change outcome	Denied — Miller did not show prejudice from lack of interview
Whether plea counsel failed to communicate regarding discovery	Counsel did not adequately provide or review discovery with Miller	Counsel hand-delivered the discovery packet and reviewed it with Miller; court found counsel credible	Denied — record shows counsel provided and reviewed discovery

Commonwealth v. Ford, 947 A.2d 1251 (Pa. Super. 2008) (standard of review for PCRA denial)
Commonwealth v. Boyd, 923 A.2d 513 (Pa. Super. 2007) (deference to PCRA court findings when record supports them)
Commonwealth v. Rathfon, 899 A.2d 365 (Pa. Super. 2006) (credibility determinations rest with PCRA court after hearing)
Commonwealth v. Dennis, 17 A.3d 297 (Pa. 2011) (binding effect of PCRA court’s credibility findings when supported by record)