Com. v. Wyatt, G., 1982 MDA 2015

In May 2013 Wyatt murdered and robbed an acquaintance; he was charged with murder, robbery, firearm offenses.
On June 2, 2014 Wyatt entered a negotiated guilty plea to third‑degree murder, robbery, possession of a firearm prohibited, and carrying a firearm without a license.
The court imposed an agreed aggregate sentence of 25 to 50 years. Wyatt later filed, then withdrew, a motion to withdraw his plea at a July 11, 2014 hearing.
Wyatt filed a timely pro se PCRA petition on June 1, 2015; counsel was appointed and filed a Turner/Finley letter seeking to withdraw.
The PCRA court issued a Rule 907 notice, denied Wyatt’s request for new counsel, and dismissed the PCRA petition without a hearing on October 13, 2015. Wyatt appealed pro se.
On appeal the Superior Court affirmed, concluding Wyatt’s claims were waived or meritless and that no evidentiary hearing was required.

Issue	Wyatt's Argument	Commonwealth's Argument	Held
Whether plea counsel was ineffective for allegedly advising a lower sentence (15–30 years) and causing an involuntary plea	Wyatt contends counsel told him the sentence would be 15–30 years, and that this erroneous advice induced his plea	Record shows plea colloquy and plea agreement stated 25–50 years; statements and hearing transcript contradict Wyatt; counsel presumed effective	Denied — claim waived or lacks arguable merit; plea was knowing, voluntary, and informed
Whether Commonwealth coerced withdrawal of motion to withdraw plea by threatening first‑degree murder charges	Wyatt claims coercion/ threat caused withdrawal and undermined plea voluntariness	Transcript shows Commonwealth had no objection to withdrawal; defense counsel informed Wyatt of possible first‑degree exposure and Wyatt affirmed his understanding	Denied — record shows no coercion; Wyatt’s statements bind him; claim lacks merit
Whether PCRA court erred in dismissing without an evidentiary hearing	Wyatt argues factual disputes require a hearing on plea voluntariness and counsel’s advice	PCRA court may decline a hearing where claims are patently without merit; record does not support Wyatt’s assertions	Denied — dismissal without a hearing was proper because claims are meritless

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes standard for ineffective assistance of counsel)
Commonwealth v. Faulk, 21 A.3d 1196 (Pa. Super. 2011) (standard of review for PCRA dismissal)
Commonwealth v. Miller, 102 A.3d 988 (Pa. Super. 2014) (PCRA court may dismiss without hearing if petition is patently frivolous)
Commonwealth v. Rathfon, 899 A.2d 365 (Pa. Super. 2006) (right to effective counsel during plea process)
Commonwealth v. Hickman, 799 A.2d 136 (Pa. Super. 2002) (ineffective assistance tied to involuntary or unknowing plea)
Commonwealth v. Bennett, 57 A.3d 1185 (Pa. 2012) (presumption of counsel effectiveness; burden on petitioner)
Commonwealth v. Jones, 815 A.2d 598 (Pa. 2002) (ineffectiveness test under state law)
Commonwealth v. Pierce, 786 A.2d 203 (Pa. 2001) (three‑part ineffective assistance test)
Commonwealth v. McCauley, 797 A.2d 920 (Pa. Super. 2001) (plea colloquy establishes voluntariness when comprehensive)
Commonwealth v. Muhammad, 794 A.2d 378 (Pa. Super. 2002) (defendant bound by statements at plea colloquy)
Commonwealth v. Stork, 737 A.2d 789 (Pa. Super. 1999) (cannot assert withdrawal grounds contradicting plea colloquy)
Commonwealth v. Yager, 685 A.2d 1000 (Pa. Super. 1996) (plea need only be knowing, voluntary, and intelligent)