Commonwealth v. Wyatt
115 A.3d 876
| Pa. Super. Ct. | 2015Background
- Kevin Wyatt was convicted in 1992 of first-degree murder, robbery, and conspiracy; he was sentenced to life on the murder and consecutive terms on robbery convictions.
- After collateral proceedings, a PCRA-based reversal led to a new trial and Wyatt pled guilty to third-degree murder in 2004; the court sentenced him to 10–20 years consecutive to earlier robbery sentences and ordered credit for “all time in this case.”
- Wyatt repeatedly filed PCRA petitions (some dismissed as untimely) and multiple habeas petitions and petitions for review challenging sentence computation by the Department of Corrections (DOC).
- In December 2010 and February 2014 Wyatt filed petitions for writ of habeas corpus arguing the DOC miscalculated his credit for time served; the trial court treated the 2014 filing as a PCRA petition and dismissed it as untimely.
- Wyatt appealed; the Superior Court agreed the trial court erred by treating the petition as a PCRA petition but nonetheless affirmed dismissal because the proper remedy was an original action in the Commonwealth Court challenging the DOC’s computation, not habeas or PCRA.
Issues
| Issue | Wyatt's Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| Whether the trial court properly treated Wyatt’s habeas petition as a PCRA petition and dismissed as untimely | Wyatt contended DOC miscalculated his credit for time served and sought relief via habeas; he argued the court erred in dismissing as an untimely PCRA filing | Commonwealth maintained collateral relief claims fall under PCRA when cognizable; court indicated some claims must go through PCRA procedure | Court held the trial court erred in characterizing the petition as PCRA (claim was DOC computation), but affirmed dismissal because habeas was not the correct vehicle; an original action in Commonwealth Court is proper |
| Proper procedural vehicle to challenge DOC computation of sentence credit | Wyatt argued habeas in trial court was appropriate to remedy DOC’s miscalculation | Commonwealth argued challenges to DOC computations must be raised in Commonwealth Court (mandamus/original action); PCRA applies only where claim attacks legality of sentence | Court held challenge to DOC computation is cognizable in Commonwealth Court as an original action (mandamus), not via habeas or PCRA |
| Whether Wyatt’s claim (DOC miscalculation) is cognizable under the PCRA | Wyatt framed issue as a post-conviction relief claim | Commonwealth and precedent: PCRA is sole means for collateral relief when claim attacks legality of sentence, but not for pure DOC computation disputes | Court held Wyatt’s claim was not cognizable under the PCRA because it disputes DOC calculation, not trial court sentence ambiguity or legality |
| Whether prior Commonwealth Court adjudications affect Wyatt’s currently asserted remedy | Wyatt continued to press DOC computation despite earlier Commonwealth Court rulings | Commonwealth noted Wyatt had litigated similar challenges in Commonwealth Court and Supreme Court affirmed outcomes against him | Court observed Wyatt had previously lost in Commonwealth Court and Supreme Court; nonetheless clarified correct procedural route is Commonwealth Court original action |
Key Cases Cited
- Commonwealth v. Heredia, 97 A.3d 392 (Pa. Super. 2014) (distinguishes DOC computation claims from trial-court sentence ambiguity; prescribes appropriate remedies)
- McCray v. Pa. Dept. of Corrections, 872 A.2d 1127 (Pa. 2005) (mandamus/original action is proper to challenge DOC computation of minimum/maximum confinement dates)
- Commonwealth v. Taylor, 65 A.3d 462 (Pa. Super. 2013) (PCRA is sole means of obtaining collateral relief when claim is cognizable under PCRA)
- Commonwealth v. Perry, 563 A.2d 511 (Pa. Super. 1989) (explains remedies for sentence-credit disputes: DOC computation v. trial-court ambiguity)
- Commonwealth v. Clouser, 998 A.2d 656 (Pa. Super. 2010) (appellate court may affirm trial court on any proper basis)