Com. v. Seldon, T., 49 EDA 2016

On July 24, 2012, Seldon participated as the getaway driver in a planned home invasion during which accomplice John Gonce shot and killed two juveniles; Seldon later was arrested.
Seldon pleaded guilty pursuant to a negotiated agreement to two counts of third‑degree murder, conspiracy, robbery, and possessing an instrument of crime, with an agreed sentence of 35 to 70 years; remaining charges were to be nol prossed.
The trial court accepted the plea and imposed the agreed sentence on July 27, 2015.
Seldon (pro se) filed a motion to withdraw his guilty plea shortly after sentencing; plea counsel moved to withdraw and new counsel was appointed.
The trial court held an evidentiary hearing and denied the motion to withdraw; Seldon appealed, arguing his plea was not knowing, intelligent, or voluntary.

Issue	Plaintiff's Argument (Seldon)	Defendant's Argument (Commonwealth/Trial Court)	Held
Whether the trial court erred by denying a post‑sentence motion to withdraw a guilty plea	Seldon: plea was not knowing/voluntary; he was surprised, pressured by counsel/DA/mother, had inadequate consultation, intended to go to trial, and the sentence amounts to a de facto life term	Trial court/Commonwealth: plea colloquy shows Seldon understood charges, rights waived, sentencing exposure, and that he entered plea voluntarily despite dissatisfaction with counsel	Court affirmed denial: plea was knowingly, intelligently, and voluntarily entered; no manifest injustice shown

Commonwealth v. Bedell, 954 A.2d 1209 (Pa. Super. 2008) (defines manifest injustice standard for withdrawing plea)
Commonwealth v. Flanagan, 854 A.2d 489 (Pa. 2004) (court may consider totality of circumstances in plea voluntariness)
Commonwealth v. Kelly, 5 A.3d 370 (Pa. Super. 2010) (defendant bound by statements made during plea colloquy)
Commonwealth v. Muhammad, 794 A.2d 378 (Pa. Super. 2002) (lack of threats or coercion during colloquy weighs against involuntariness)