Com. v. Robinson, L.
Com. v. Robinson, L. No. 1523 EDA 2016
| Pa. Super. Ct. | Jun 6, 2017Background
- Robinson pleaded open guilty on June 11, 2007 to charges arising from a violent home invasion involving aggravated assault and sexual assaults; consolidated sentencing resulted in an aggregate term of 88½ to 177 years after reconsideration.
- A Megan’s Law assessment found Robinson a sexually violent predator.
- Robinson filed a timely PCRA petition (filed July 18, 2011; amended Oct. 27, 2015) asserting his guilty plea was unlawfully induced and that trial counsel was ineffective for causing an involuntary/unknowing plea and failing to pursue competency.
- The PCRA court reviewed the plea colloquy, written plea form, mental-health reports, prison recordings, and other record materials and issued a Pa.R.Crim.P. 907 notice; the petition was dismissed April 25, 2016 for lack of merit.
- The court concluded the plea was knowing, intelligent, and voluntary (despite medication), found no genuine issues of material fact warranting an evidentiary hearing, and rejected claims of incompetence based on later evaluations that found malingering.
Issues
| Issue | Robinson's Argument | Commonwealth / Trial Court's Argument | Held |
|---|---|---|---|
| Whether an evidentiary hearing was required before dismissing the PCRA petition | Court should have held a hearing to develop facts supporting plea coercion and counsel ineffectiveness | No genuine dispute of material fact; record (colloquy, written plea, records) resolves claims; hearing would serve no purpose | Denied — no hearing required where claims are patently without merit and resolvable on record |
| Whether the guilty plea was unlawfully induced / involuntary | Plea was induced or involuntary (due to medication/mental state) and therefore voidable | Plea colloquy and written waiver show Robinson understood charges, penalties, and voluntarily admitted factual basis; being medicated does not automatically invalidate plea | Denied — plea was knowing, intelligent, and voluntary |
| Whether Robinson was incompetent at time of plea | Mental-health evaluation after plea shows severe deficits; counsel ineffective for not requesting competency hearing | Court observed Robinson as lucid during colloquy; later evaluations (Norristown) found malingering; recordings show Robinson admitted intent to feign illness | Denied — competency not shown; no basis for relief |
| Whether trial counsel was ineffective for causing involuntary plea or failing to pursue competency | Counsel’s conduct caused involuntary plea and failed to protect Robinson's rights | Under Pierce/Koehler standards, underlying claims lacked arguable merit and Robinson failed to show causal link between counsel’s acts and an involuntary plea | Denied — ineffective assistance claim fails (no arguable merit; no causal link) |
Key Cases Cited
- Payne v. Commonwealth, 794 A.2d 902 (Pa. Super. 2002) (PCRA evidentiary-hearing analysis: no hearing when record disposes of claims)
- Fluharty v. Commonwealth, 632 A.2d 312 (Pa. Super. 1993) (standard for unlawfully induced guilty plea; plea must be involuntary/unknowing)
- Willis v. Commonwealth, 68 A.3d 997 (Pa. Super. 2013) (medication or mental illness does not automatically preclude a knowing, voluntary plea; competency assessed by colloquy and court observation)
- Cottrell v. Commonwealth, 249 A.2d 294 (Pa. 1969) (factual basis and significant evidence of guilt can support finding plea was voluntary despite limited defendant detail in court)
- Koehler v. Pennsylvania, 36 A.3d 121 (Pa. 2012) (ineffective-assistance framework; counsel not ineffective for failing to raise meritless claims)