Com. v. Satcher, R.
Com. v. Satcher, R. No. 2194 EDA 2016
| Pa. Super. Ct. | Jun 23, 2017Background
- Appellant Randall L. Satcher Jr. participated in an October 2013 home invasion; he assaulted a victim and was charged with multiple offenses, including robbery and conspiracy.
- On August 5, 2015, after trial began, Satcher entered a negotiated guilty plea to one count of robbery and one count of conspiracy and received 5–10 years’ incarceration plus five years’ probation.
- He did not move to withdraw the plea or file a direct appeal. A timely, pro se PCRA petition was filed on December 28, 2015; counsel was appointed and later filed to withdraw.
- The PCRA court issued Rule 907 notice, received no response from Satcher, and dismissed the petition on June 9, 2016, without an evidentiary hearing; Satcher appealed pro se.
- Satcher’s PCRA claimed ineffective assistance of plea counsel for failing to challenge an identification, denying confrontation at the preliminary hearing, and permitting hearsay testimony; he also argued the petition’s dismissal without a hearing was error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Counsel ineffective for failing to challenge victim identification | Satcher: counsel should have contested a faulty identification that did not match him | Commonwealth: plea waived most pretrial challenges; record and brief lack developed argument | Waived for inadequate briefing; claim not developed, therefore dismissed |
| Counsel denied right to confront accuser at preliminary hearing | Satcher: counsel failed to protect confrontation rights at prelim hearing | Commonwealth: errors at preliminary hearing cannot show prejudice after guilty plea | Denied — preliminary hearing errors cannot establish prejudice post-plea |
| Counsel allowed detective to testify to co-defendant’s statement (hearsay) | Satcher: admission of Favors’ statement through detective violated confrontation | Commonwealth: same as above — preliminary-hearing issues not cognizable after plea | Denied — no prejudice shown because of guilty plea |
| PCRA court erred by dismissing petition without evidentiary hearing | Satcher: his claims required an evidentiary hearing | Commonwealth: claims patently meritless or waived; court may dismiss under Pa.R.Crim.P. 907 | Denied — PCRA court acted within discretion; no genuine issue requiring hearing |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes ineffective assistance test)
- Pierce v. Commonwealth, 786 A.2d 203 (Pa. 2001) (prejudice test for ineffective assistance in Pennsylvania)
- Commonwealth v. Sanchez, 82 A.3d 943 (Pa. 2013) (errors at preliminary hearing cannot establish prejudice after guilty plea)
- Commonwealth v. Miller, 102 A.3d 988 (Pa. Super. 2014) (standard for dismissing PCRA without evidentiary hearing)
- Commonwealth v. McCauley, 797 A.2d 920 (Pa. Super. 2001) (plea colloquy and totality-of-circumstances analysis for voluntariness)