Com. v. Zeigler, Q.
2000 MDA 2016
| Pa. Super. Ct. | Sep 26, 2017Background
- Quilie Zeigler pled guilty on December 17, 2013 to drug and firearm offenses pursuant to a negotiated plea and received a mandatory 5–10 year sentence. He did not file a direct appeal.
- Zeigler filed multiple pro se PCRA petitions: first in August 2014 (counsel appointed, counsel filed Turner/Finley no‑merit and petition dismissed), second in March 2015 (counsel withdrew and petition dismissed), a third in August 2015 (not entertained), and a fourth on October 3, 2016.
- The PCRA court issued a notice of intent to dismiss the October 2016 petition on November 16, 2016, dismissed the petition in December 2016, and informed Zeigler of appeal rights. Zeigler appealed pro se.
- Zeigler argued his mandatory minimum sentence is unconstitutional (relying on Hopkins/Alleyne reasoning) and that PCRA timeliness constraints are themselves unconstitutional when they bar correction of illegal sentences.
- The PCRA court dismissed the October 2016 petition as untimely; the Superior Court affirmed for lack of jurisdiction because Zeigler failed to plead a timely exception to the one‑year statutory time bar.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the PCRA petition challenging mandatory minimum sentence was timely | Zeigler: his sentence is illegal post‑Hopkins/Alleyne; PCRA relief warranted despite delay | Commonwealth: petition filed more than one year after finality; timeliness is jurisdictional and no exception was pled | Petition untimely; no jurisdiction because Zeigler did not plead a valid exception |
| Whether a new constitutional rule (mandatory minimums invalidated) excuses timeliness | Zeigler: newly recognized constitutional right (Alleyne/Hopkins) applies retroactively to his sentence | Commonwealth: Hopkins involved direct appeal timing; Zeigler’s sentence was final before those decisions and he failed 60‑day filing requirement | Court rejected reliance on Hopkins; Zeigler did not satisfy the 60‑day/one‑year exceptions |
| Whether legality‑of‑sentence claims escape PCRA time limits | Zeigler: time limits unconstitutional when they bar correction of illegal sentences | Commonwealth: legality claims remain subject to PCRA timeliness requirements | Court: legality claims still must satisfy PCRA time limits or an exception; time bar applies |
| Whether the PCRA court should treat his habeas styling differently | Zeigler: styled claims as habeas corpus relief | Commonwealth: PCRA is the exclusive remedy for collateral relief of this type | Court treated claim as PCRA claim properly and dismissed as untimely |
Key Cases Cited
- Turner, 544 A.2d 927 (Pa. 1988) (establishes counsel withdrawal/no‑merit letter procedure in PCRA representation)
- Finley, 550 A.2d 213 (Pa. Super. 1988) (addresses appellate counsel no‑merit procedures under PCRA)
- Ousley v. Commonwealth, 21 A.3d 1238 (Pa. Super. 2011) (standard of review for PCRA denial)
- Brown v. Commonwealth, 111 A.3d 171 (Pa. Super. 2015) (timeliness of PCRA petitions is jurisdictional)
- Hopkins v. Commonwealth, 117 A.3d 247 (Pa. 2015) (addressed constitutionality of mandatory minimum under Alleyne in direct‑appeal posture)
- Alleyne v. United States, 133 S. Ct. 2151 (U.S. 2013) (holding facts increasing mandatory minimum must be found by jury)
- Infante v. Commonwealth, 63 A.3d 358 (Pa. Super. 2013) (legality of sentence claims remain subject to PCRA time limits)
- Fowler v. Commonwealth, 930 A.2d 586 (Pa. Super. 2007) (PCRA timeliness principles)
- Hall v. Commonwealth, 771 A.2d 1232 (Pa. 2001) (PCRA is exclusive vehicle for collateral relief)