Com. v. Valenti, I., 397 MDA 2015

Isaiah S. Valenti was convicted (Oct. 17, 2008) of drug and related offenses and sentenced to 11–27 years’ imprisonment.
Valenti filed multiple PCRA petitions; the trial court granted nunc pro tunc relief once but the Superior Court later found that relief improperly granted and reinstated the earlier PCRA denial, remanding unresolved claims for hearing.
A PCRA hearing on January 9, 2015 addressed two claims relating to trial counsel’s failure to object to or obtain a ruling on an ADA statement and sentencing references; the court denied relief on January 15, 2015 and denied reconsideration on January 29, 2015.
Valenti filed a notice of appeal on February 26, 2015; the Superior Court treated the appeal as facially untimely but found a court-process breakdown (trial court’s statement inviting a reconsideration motion) excused strict timeliness and allowed the appeal to proceed.
PCRA counsel submitted a Turner/Finley no‑merit letter and petition to withdraw; counsel made a minor procedural error in advising Valenti about post‑withdrawal options, but the court found substantial compliance and ordered the defendant’s response.
The Superior Court concluded Valenti’s ineffective‑assistance claims were waived (not raised in the first PCRA) and, because this was a second/subsequent PCRA, he failed to make the heightened prima facie showing of a miscarriage of justice; the court affirmed the denial and granted counsel’s withdrawal.

Issue	Valenti's Argument	Commonwealth's Argument	Held
1) Was the appeal timely?	Court’s instruction to file reconsideration misled Valenti and tolled the appeal period.	Notice of appeal filed late; 30‑day PCRA appeal rule applies and is jurisdictional.	Trial court’s statement created an administrative breakdown; appeal not quashed.
2) Was trial counsel ineffective for failing to press objections / obtain rulings regarding ADA statements and sentencing comments?	Trial counsel failed to ask the court to rule on objections and failed to challenge sentencing references, constituting ineffective assistance.	Issues were waived because not raised in first PCRA; as a successive PCRA, Valenti failed to show a miscarriage of justice or actual innocence.	Claims waived and insufficient to meet the heightened standard for a second/subsequent PCRA; relief denied.

Turner, 544 A.2d 927 (Pa. 1988) (outlines procedural requirements when counsel seeks to withdraw from PCRA representation)
Finley, 550 A.2d 213 (Pa. Super. 1988) (companion decision to Turner governing no‑merit letters and withdrawal)
Leatherby v. Commonwealth, 116 A.3d 73 (Pa. Super. 2015) (court process breakdown can excuse procedural defaults)
Moir v. Commonwealth, 766 A.2d 1253 (Pa. Super. 2000) (motion for reconsideration does not toll the 30‑day PCRA appeal period)
Doty v. Commonwealth, 48 A.3d 451 (Pa. Super. 2012) (trial court must independently review Turner/Finley submissions before permitting withdrawal)
Medina, 92 A.3d 1210 (Pa. Super. 2014) (en banc) (heightened prima facie showing required for second or subsequent PCRA petitions)
Spotz v. Commonwealth, 84 A.3d 294 (Pa. 2014) (standard of review for PCRA denials)