Commonwealth v. Seskey, 170 A.3d 1105

Seskey, a minor, was convicted of first-degree murder for the 1992 killing of Marc Bova and received LWOP under then-mandatory statutes.
The murder occurred after Seskey and a co-conspirator lured the victim to a field and Seskey fired a sawed-off shotgun five times, killing him.
Post-conviction relief petitions were filed in 1997, 1998, 2010, and 2012, with the Supreme Court denying relief on direct and prior PCRA iterations.
After Montgomery v. Louisiana, Seskey filed a third PCRA petition in January 2016, which the court granted, resentencing him to 13–26 years.
Commonwealth appealed, asserting the court erred by not imposing a maximum life sentence; Seskey argued the court had unfettered discretion on resentencing.
The Superior Court vacated the 26-year maximum, held that Batts II requires a maximum life sentence for pre-Miller juvenile murderers, and remanded for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence was illegal for not imposing a life maximum	Commonwealth: max must be life; 26 years unlawful	Seskey: trial court has unfettered discretion on minimum	Illegal sentence; must be life maximum
Whether Batts II/comparative law requires life maximum with minimum set by court	Commonwealth: Batts II supports life max with defined minimum	Seskey: discretion to set any minimum within framework	Batts II requires life maximum for pre-Miller offenders

Commonwealth v. Batts, 66 A.3d 286 (Pa. 2013) (pre-Miller framework for juveniles convicted of murder; severed provisions applicable to LWOP)
Commonwealth v. Vazquez, 744 A.2d 1280 (Pa. 2000) (illegality of mandatory sentencing implicates legality of sentence)
Commonwealth v. Barnes, 151 A.3d 121 (Pa. 2016) (legality of sentences and evaluation of parole eligibility)
Montgomery v. Louisiana, 136 S. Ct. 718 (S. Ct. 2016) (retroactivity of Miller v. Alabama to juvenile offenders)