Com. v. Muhammad, L.
3165 EDA 2016
| Pa. Super. Ct. | Oct 18, 2017Background
- Victim Ravi Ghattamaneni met Muhammad at Parx Casino; Ghattamaneni left with $3,100 in an envelope after gambling; surveillance placed both at the table and following Ghattamaneni outside.
- Ghattamaneni and Muhammad rode together; surveillance and a McDonald’s receipt corroborated stops; Ghattamaneni alleges Muhammad brandished a folding knife, took his phone and the envelope money, and pushed him from the car on I‑95.
- Police recovered surveillance video, clothing matching casino footage, a folding box cutter from Muhammad’s vehicle, and McDonald’s receipts during searches.
- Muhammad pled guilty (open plea) to robbery, terroristic threats, and PIC on June 7, 2016; sentencing deferred to Sept. 9, 2016.
- Muhammad filed a counseled motion to withdraw his guilty plea the day before sentencing asserting innocence and emotional regret; the trial court denied the motion and imposed an aggregate 5–10 year sentence.
- Muhammad appealed, raising that the trial court abused its discretion by denying his pre‑sentence motion to withdraw the plea; the Superior Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion in denying Muhammad’s pre‑sentence motion to withdraw his guilty plea | Commonwealth: denial proper because plea was supported by factual record and withdrawal would not promote fairness | Muhammad: moved pre‑sentence asserting innocence and regret, claiming a fair and just reason to withdraw plea | Trial court did not abuse discretion; Superior Court affirmed denial — Muhammad’s claim implausible given evidence and record |
Key Cases Cited
- Lord, 719 A.2d 306 (Pa. 1998) (requirements for preserving issues via Pa.R.A.P. 1925(b))
- Bedell, 954 A.2d 1209 (Pa. Super. 2008) (plea must be knowingly, voluntarily, intelligently entered)
- Morrison, 878 A.2d 102 (Pa. Super. 2005) (topics required in plea colloquy)
- Gordy, 73 A.3d 620 (Pa. Super. 2013) (standard of review for withdrawal of guilty plea)
- Carrasquillo, 115 A.3d 1284 (Pa. 2015) (pre‑sentence withdrawal should be liberally allowed for fair and just reasons)
- Thompson, 39 A.3d 335 (Pa. Super. 2012) (untimely Rule 1925(b) statements may be addressed on merits if trial court considered issues)
- Ali, 10 A.3d 282 (Pa. 2010) (pro se filings by represented defendants are generally legal nullities)
- Mason, 130 A.3d 601 (Pa. 2015) (discussing hybrid representation and counsel control)