Commonwealth v. Moore, I., Aplt., 247 A.3d 990

Ingram Moore was convicted of first-degree murder in 1995 and sentenced to life imprisonment without parole under 18 Pa.C.S. § 1102(a); his judgment of sentence became final in 1998.
In 2015–2016 Moore filed state habeas petitions asserting § 1102(a) is unconstitutionally vague for failing to notify defendants that "life" means without parole.
The trial court (after appointed counsel filed a Finley letter) treated the filings as PCRA petitions and dismissed them as untimely under the PCRA.
The Superior Court affirmed, characterizing Moore’s claim as an illegal-sentence claim cognizable under the PCRA.
Moore argued (and Rouse earlier held for § 1102(b)) that a void-for-vagueness challenge to a sentencing statute is properly raised in habeas, not under the PCRA.
The Supreme Court of Pennsylvania held the vagueness challenge is an illegal-sentence claim cognizable under the PCRA, rejected Rouse, and affirmed dismissal because Moore’s petition was untimely and the court lacked jurisdiction to reach the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a void-for-vagueness challenge to a sentencing statute must be raised in a habeas petition or under the PCRA	Moore: Vagueness claim is not one of the § 9543(a)(2) PCRA categories and thus belongs in habeas	Trial court/Superior Court: Claim attacks sentence legality and is cognizable under the PCRA	Court: Vagueness challenge to a sentencing statute is an illegal-sentence claim cognizable under the PCRA
Whether this case conflicts with Superior Court’s decision in Rouse (holding a § 1102(b) vagueness claim was habeas, not PCRA)	Moore: Rouse supports habeas treatment; Moore's claim is the same as Rouse	Superior Court had held Rouse’s claim was not an illegal-sentence claim	Court: Rejects Rouse; Rouse was incorrect — such vagueness claims fall within PCRA cognizability (Barnes/DiMatteo framework)
Effect of PCRA timeliness on Moore’s petition and jurisdiction	Moore: (implicit) treated as habeas so not subject to PCRA timeliness	Commonwealth/trial court: Because claim is cognizable under PCRA, PCRA timeliness rules apply	Court: PCRA timeliness is jurisdictional; Moore’s petition was untimely (final in 1998) with no exception, so dismissal affirmed for lack of jurisdiction

Commonwealth v. Barnes, 151 A.3d 121 (Pa. 2016) (explains when an Alleyne-type sentencing error renders a sentence illegal)
Commonwealth v. DiMatteo, 177 A.3d 182 (Pa. 2018) (applies Barnes and holds Alleyne claims can be raised under the PCRA)
Commonwealth v. Rouse, 191 A.3d 1 (Pa. Super. 2018) (Superior Court held a § 1102(b) vagueness claim belonged in habeas)
Alleyne v. United States, 570 U.S. 99 (2013) (holds facts increasing mandatory penalties must be found by jury)
Johnson v. United States, 576 U.S. 591 (2015) (discusses void-for-vagueness doctrine in criminal statutes)
Commonwealth v. McIntyre, 232 A.3d 609 (Pa. 2020) (sentence under statute void ab initio implicates sentence legality)
Commonwealth v. Fahy, 737 A.2d 214 (Pa. 1999) (timeliness and cognizability principles under the PCRA)
Commonwealth v. Bennett, 930 A.2d 382 (Pa. 2007) (PCRA timeliness is jurisdictional)