Com. v. Slater, J., 1934 WDA 2015

James Robert Slater was convicted at jury trial in 2008 of multiple sexual offenses involving a minor; sentences totaled consecutive prison terms, later affirmed on direct appeal and allowance of appeal denied.
Slater filed a pro se PCRA petition in 2011; after counsel was appointed and an evidentiary hearing, the PCRA court granted relief and Slater entered a negotiated guilty plea in 2013 to all counts and was sentenced to 7.5 to 15 years plus lifetime registration; no direct appeal was taken.
Slater filed a subsequent pro se PCRA petition in 2014 alleging plea-counsel ineffectiveness for promising parole at his minimum sentence, seeking to withdraw his guilty plea; counsel was appointed and an evidentiary hearing was held in November 2015.
At the PCRA hearing Slater testified that counsel said he "could make parole" but conceded counsel did not promise a "hundred percent"; plea counsel denied ever guaranteeing parole and testified she does not make such promises.
The PCRA court credited plea counsel’s testimony, found Slater’s plea knowing, voluntary, and intelligent, and denied relief; this appeal followed and PCRA appellate counsel filed a Turner/Finley no‑merit brief and motion to withdraw.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plea counsel ineffectively induced Slater's guilty plea by promising parole	Slater: counsel promised he would be paroled on his minimum sentence, so his plea was unlawfully induced and involuntary	Commonwealth/PCRA court: counsel denied guaranteeing parole; plea colloquy and testimony show no promise; plea was voluntary	Denied — PCRA court credited counsel, Slater hedged his claim, and plea found knowing and voluntary
Whether the PCRA court erred in denying relief based on plea‑counsel credibility	Slater: trial court should not have believed counsel over him	Commonwealth: credibility determinations are for the PCRA court and are entitled to deference	Denied — appellate court deferred to PCRA court findings and upheld credibility determination
Whether appellate counsel complied with Turner/Finley withdrawal requirements	Slater: (implicit) counsel should not withdraw or failed to preserve issues	Appellate counsel: submitted Turner/Finley no‑merit letter explaining review and sent required notices	Granted — court found Turner/Finley requirements satisfied and permitted withdrawal

Commonwealth v. Rollins, 738 A.2d 435 (Pa. 1999) (presumption counsel effective; three‑part ineffectiveness test)
Commonwealth v. Travaglia, 661 A.2d 352 (Pa. 1995) (arguable merit component of ineffectiveness analysis)
Commonwealth v. Barnes, 687 A.2d 1163 (Pa. 1997) (defendant bound by statements at plea colloquy)
Commonwealth v. Pitts, 981 A.2d 875 (Pa. 2009) (Turner/Finley counsel must conduct independent review and file no‑merit letter)
Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988) (procedural framework for withdrawal of counsel on collateral appeal)
Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (Turner companion case on no‑merit filings)