Com. v. Vansyckel, G., Com. v. Vansyckel, G. No. 1777 MDA 2016

Appellant Gina Vansyckel pleaded open guilty to multiple counts: two burglaries and four related conspiracy counts arising from entering unoccupied homes in Reading, PA.
Plea colloquy established she and co-conspirators entered vacant/for-sale residences intending to commit burglary; she cooperated with police.
At sentencing the Commonwealth calculated guideline ranges (offense gravity scores 6–7); recommended bottom-of-range sentences. A pre-sentence investigation report was available to the court.
Defense urged mitigation based on employment, volunteer work, letters of support, lack of violent conduct, and severe COPD/health concerns; requested intermediate punishment or house arrest.
Trial court (initially inclined to exceed the Commonwealth recommendation) imposed concurrent standard-range terms: two burglary counts 35–90 months plus probation, and concurrent 2–4 year terms on conspiracy counts, citing seriousness of burglaries despite considering letters and health.
Appellant filed a post-sentence motion and timely appealed. Appellate counsel filed an Anders/Santiago brief and petition to withdraw. The Superior Court reviewed discretionary-sentencing claims and granted counsel’s withdrawal request, affirming the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Appellant's standard-range concurrent sentences were an abuse of discretion because the court overemphasized offense gravity and failed to account for rehabilitative needs / state reasons on record under 42 Pa.C.S. § 9721(b)	Vansyckel argued the court focused unduly on offense gravity and victims’ impact and failed to adequately consider or state reasons relating to her rehabilitative needs and health	Trial court and Commonwealth pointed out the sentences were within the standard guideline ranges, the court had the PSI, considered letters and health, and expressly stated reasons for imposing sentence based on seriousness and prior theft history	The Superior Court held no abuse of discretion: standard-range concurrent sentences supported by PSI and on-record reasons; sentencing court considered mitigation and properly imposed sentence; claim meritless

Anders v. California, 386 U.S. 738 (U.S. 1967) (standards for counsel seeking withdrawal on appeal)
Commonwealth v. Santiago, 978 A.2d 349 (Pa. 2009) (procedural requirements for Anders-style briefs in Pennsylvania)
Commonwealth v. Moury, 992 A.2d 162 (Pa. Super. 2010) (what constitutes a substantial question for discretionary sentencing review)
Commonwealth v. Walls, 926 A.2d 957 (Pa. 2007) (sentencing must consider protection of public, offense gravity, and rehabilitative needs; reasons must be stated)
Commonwealth v. Corley, 31 A.3d 293 (Pa. Super. 2011) (standard-range sentences with PSI are presumed not excessive)
Commonwealth v. Coss, 695 A.2d 831 (Pa. Super. 1997) (PSI on record can satisfy requirement that trial court state reasons for sentence)