Com. v. Youngquist, K.
49 WDA 2017
| Pa. Super. Ct. | Nov 20, 2017Background
- On June 6, 2015, Youngquist and Thomas Johnson fought at their residence; Johnson suffered a broken jaw and Youngquist admitted to police he punched Johnson. Commonwealth charged Youngquist with simple assault and harassment.
- After continuances and jury selection, the Commonwealth amended the information to add disorderly conduct (18 Pa.C.S. § 5503(a)(1)).
- On August 4, 2016, Youngquist entered an open guilty plea to disorderly conduct, admitted the factual basis, and agreed to $9,436.40 restitution; other charges were nolle prossed.
- New counsel appeared; Youngquist moved on September 6, 2016 to withdraw his guilty plea before sentencing, asserting he misunderstood the facts, evidence, burden of proof, sentencing exposure, and asserting innocence.
- The trial court denied the pre‑sentence motion after finding Youngquist’s claim of innocence implausible given his admissions to police and in court and that the plea colloquy satisfied Pa.R.Crim.P. 590(A)(3).
- Court sentenced Youngquist to 7 days to 1 year (credit for 7 days served) and immediate parole eligibility; Superior Court affirmed denial of plea withdrawal on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court abused discretion denying pre‑sentence motion to withdraw guilty plea | Trial court should allow withdrawal because plea was entered without full review of discovery, without understanding of defenses, burden of proof, or sentencing exposure | Youngquist argued his plea was not voluntary or understandingly entered and asserted innocence | Denial affirmed; bare claim of innocence implausible given admissions and valid colloquy; no abuse of discretion |
Key Cases Cited
- Commonwealth v. Carrasquillo, 115 A.3d 1284 (Pa. 2015) (pre‑sentence withdrawal of plea permitted for any fair and just reason, but bare claim of innocence insufficient)
- Commonwealth v. Forbes, 299 A.2d 268 (Pa. 1973) (trial court may allow withdrawal prior to sentence for fair and just reason unless prosecution substantially prejudiced)
- Commonwealth v. Dickter, 465 A.2d 1 (Pa. Super. 1983) (pre‑sentence plea withdrawals generally liberally allowed)
- Commonwealth v. Hill, 16 A.3d 484 (Pa. 2011) (untimely Rule 1925(b) statement generally waives issues on appeal)
- Commonwealth v. Burton, 973 A.2d 428 (Pa. Super. 2009) (late Rule 1925(b) filing when counsel represents defendant may indicate per se ineffectiveness)
- Commonwealth v. Grohowski, 980 A.2d 113 (Pa. Super. 2009) (appellate court may address merits where trial court filed an opinion despite untimely 1925(b) statement)
- Commonwealth v. Cameron, 780 A.2d 688 (Pa. Super. 2001) (abuse of discretion review standard for plea withdrawal decisions)