Commonwealth v. Riggle, 119 A.3d 1058

Riggle convicted by jury of involuntary deviate sexual intercourse, aggravated indecent assault, corruption of a minor, and indecent assault involving his thirteen-year-old nephew M.B. and received an 8–16 year term with a five-year mandatory minimum; sentence based on § 9718(a)(1).
Appellant challenged the sentencing framework, arguing Alleyne retroactivity and improper mandatory minimum application.
PCRA petition alleging trial counsel ineffective for failing to call witnesses, impeach witnesses, obtain medical records, address date specificity, and object to closing remarks; counsel filed a no-merit letter.
PCRA court denied relief and permitted counsel to withdraw; Riggle appealed from the denial.
Court previously noted confusion over Alleyne’s retroactivity and Teague framework and conducted independent review of the record for legal error.
Appellant reserved rights to supplemental statements, but did not file them; issues on appeal include sentencing legality under Alleyne and ineffective assistance claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the Alleyne ruling retroactive under Teague for collateral review?	Riggle seeks Alleyne retroactivity on PCRA review.	Riggle is not entitled to Alleyne retroactivity in PCRA.	Alleyne not retroactive on collateral review.
Was trial counsel ineffective for failing to object to prosecutorial closing remarks?	Closing remarks were inflammatory and improper; counsel should have objected.	Remarks were within proper closing argument and supported by evidence.	No ineffectiveness; remarks were supported and defended as proper response.
Was trial counsel ineffective for not presenting expert impeachment of Denise Scott?	Experts could have contradicted Scott’s testimony.	Scott’s testimony not central to guilt; impeachment unlikely to change outcome.	No ineffective assistance for failure to present impeachment.
Did lack of specific dates for offenses render the defense unfair or improper?	Indictment’s eight-month window insufficient to prepare a defense.	Dates need not be exact; continuous conduct allowed; broad latitude exists.	Not a due process violation; dates were sufficiently fixed.
Should PCRA counsel have withdrawn with a no-merit letter given meritorious issues?	Meritorious issues existed, including Alleyne-related concerns.	No-merit letter proper; issues did not merit relief under law.	No reversible error; withdrawal appropriate.

Commonwealth v. Freeland, 106 A.3d 768 (Pa. Super. 2014) (standard for reviewing PCRA findings of fact and legal conclusions)
Alleyne v. United States, 133 S. Ct. 2151 (2013) (requires jury finding beyond a reasonable doubt for mandatory-minimum enhancements)
Watley, 81 A.3d 108 (Pa. Super. 2013) (distinguishes direct appeal retroactivity from collateral review retroactivity)
Newman, 99 A.3d 86 (Pa. Super. 2014) (direct appeal retroactivity; not controlling for collateral review)
Teague v. Lane, 489 U.S. 288 (1989) (retroactivity framework for new constitutional rules in collateral review)
Gideon v. Wainwright, 372 U.S. 335 (1963) (watershed procedural rule: right to counsel)