Com. v. Steele, C., 19 WDA 2021

On March 27, 2018, Steele chased and shot at a red Nissan Sentra after an alleged drug-sale robbery; the Sentra then crashed into parked cars. Steele fled the scene.
Police stopped Steele ~45 minutes later and found a warm .22 Smith & Wesson under the passenger seat with an empty magazine, shell casings, gunshot residue on Steele, and a police scanner app running on his phone.
A jury convicted Steele of multiple offenses; trial court sentenced him to 66–144 months plus probation. On direct appeal, this Court vacated only the criminal use of a communication facility conviction and remanded for resentencing; Steele was resentenced to 60–144 months and three years’ probation.
Steele filed a pro se PCRA petition claiming trial counsel was ineffective for failing to enforce a magisterial-level plea agreement (arguing he was deprived of the bargain). Counsel was appointed and supplemented the petition.
The PCRA court issued a Rule 907 notice and dismissed the petition without a hearing; it concluded Steele had declined to enter a guilty plea at the scheduled plea hearing and therefore no enforceable plea existed and counsel was not ineffective.
Steele appealed; the Superior Court affirmed, holding the plea was unenforceable (magisterial judge lacked jurisdiction for some offenses), Steele never intended to plead guilty, and his ineffective-assistance claim lacked merit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether PCRA court abused discretion by denying relief for trial counsel’s alleged failure to enforce a magisterial-level plea agreement (depriving Steele of the plea bargain)	Steele: A plea was negotiated at the magisterial level and trial counsel failed to enforce it, causing prejudice by denying him the opportunity to enter those plea terms before the trial court	Commonwealth/PCRA court: Steele withdrew/declined the plea at the plea hearing; the magisterial judge lacked jurisdiction to accept plea to certain charges; the agreement was not a binding plea; counsel was not ineffective	Court affirmed dismissal: plea was not binding/enforceable, Steele chose not to plead, and the ineffective-assistance claim failed (procedural pleading deficiencies and merits).

Commonwealth v. Steele, 234 A.3d 840 (Pa. Super. 2020) (vacating criminal-use-of-communication-facility conviction and directing resentencing)
Commonwealth v. Reyes-Rodriguez, 111 A.3d 775 (Pa. Super. 2015) (standard and scope of review in PCRA appeals)
Commonwealth v. Blakeney, 108 A.3d 739 (Pa. 2014) (standards for dismissing a PCRA petition without a hearing)
Commonwealth v. Johnson, 966 A.2d 523 (Pa. 2009) (Pennsylvania test for ineffective assistance of counsel)
Commonwealth v. Pettus, 424 A.2d 1332 (Pa. 1981) (defendant may not assert ineffectiveness in a vacuum)
Commonwealth v. Epps, 240 A.3d 640 (Pa. Super. 2020) (affirmance of PCRA denial where procedural/merit defects are present)