guilty plea hearing (Pennsylvania) · Go Syfert
← Pennsylvania issues

guilty plea hearing in Pennsylvania

154 Pennsylvania opinions name it 4 courts 1968–2026 53 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (51)

CaseFollowedCited
Commonwealth v. Willisgreen
pasuperct · 2013 · cited in 6 Pennsylvania opinions naming this issue, 2015–2022
2 sentences

2022See Commonwealth v. Willis, 68 A.3d 997, 1009 (Pa. Super. 2013) (“Appellant is bound by these statements, which he made in open court while under oath, and he may not now assert grounds for withdrawing the plea which contradict the statements.”).

2021In Commonwealth v. Willis, 68 A.3d 997 (Pa. Super. 2013), a panel of this Court similarly found: [D]espite [Willis’] self-serving testimony that he felt “tranquilized” during the guilty plea hearing, [Willis’] guilty plea counsel indicated [Willis] appeared to be competent, he did not appear to be “tranquilized,” his speech was not slurred, and he provided appropriate answers to questions.

56
Commonwealth v. Tareilagreen
pasuperct · 2006 · cited in 5 Pennsylvania opinions naming this issue, 2015–2021
2 sentences

2021As noted above, in order to preserve an issue related to the validity of a guilty plea, a defendant must either object during the colloquy or otherwise raise the issue at the guilty plea hearing, sentencing hearing or in post-sentence motions.8 Lincoln, ____________________________________________ 8 Indeed, “[p]ost-sentence motions for withdrawal are subject to higher scrutiny since courts strive to discourage the entry of guilty pleas as sentencing-testing devices.” Commonwealth v. Kpou, 153 A.3d 1020, 1023 (Pa. Super. 2016). -8- supra; accord: Commonwealth v. Tareila, 895 A.2d 1266 , 1270 n.

2021As noted above, in order to preserve an issue related to the validity of a guilty plea, a defendant must either object during the colloquy or otherwise raise the issue at the guilty plea hearing, sentencing hearing, or in a post-sentence motion.8 Lincoln, supra; accord Commonwealth v. Tareila, 895 A.2d 1266 , 1270 n.3 (Pa. Super. 2006); see also Pa.R.A.P. 302(a) (“Issues not raised in the lower court are waived and cannot be raised for the first time on appeal.”). ____________________________________________ 8 Indeed, “[p]ost-sentence motions for withdrawal are subject to higher scrutiny since

45
Commonwealth v. Floodgreen
pasuperct · 1993 · cited in 4 Pennsylvania opinions naming this issue, 2014–2018
2 sentences

2018In order to obtain relief on a claim alleging that counsel provided ineffective assistance of counsel during a guilty plea hearing, a defendant must prove "a causal nexus between counsel's ineffectiveness, if any, and an unknowing or involuntary plea" by showing that he or she "was misled or misinformed and acted under that misguided influence when entering the guilty plea." Commonwealth v. Flood, 627 A.2d 1193, 1199 (Pa. Super. 1993).

2017The focus of the inquiry is whether the accused was misled or misinformed and acted under that misguided influence when entering the guilty plea. -8- J-S59045-17 Commonwealth v. Flood, 627 A.2d 1193, 1199 (Pa. Super. 1993) (citations and quotation marks omitted).

44
Commonwealth v. McCauleygreen
pasuperct · 2001 · cited in 5 Pennsylvania opinions naming this issue, 2014–2021
2 sentences

2020In arriving at that conclusion, the court noted that Appellant’s responses during the guilty plea hearing “indicate[d] that he knew he agreed to the specific negotiated sentence of imprisonment.” Id.; see Commonwealth v. McCauley, 797 A.2d 920 (Pa.Super. 2001) (holding that where the record demonstrates that a guilty plea colloquy was conducted that reflects that the petitioner understood the nature of the charges, voluntariness of the plea is established).

2015See McCauley, supra. Our review of the guilty plea hearing transcript and documents reveals that the lower court did not abuse its discretion.

35
Commonwealth v. Bedellgreen
pasuperct · 2008 · cited in 4 Pennsylvania opinions naming this issue, 2015–2018
2 sentences

2018Bedell, supra. Moreover, although a written colloquy was prepared in this matter, it was not signed by Martin, nor did he initial any of its pages, as is common practice, to demonstrate that he had read the document.

2015See Bedell, 954 A.2d at 1212-13 .

34
Commonwealth v. Monjaras-Amayagreen
pasuperct · 2017 · cited in 3 Pennsylvania opinions naming this issue, 2024–2025
2 sentences

2025“The purpose of this waiver rule is to allow the trial court to correct its errors at the first opportunity, and, in doing, further judicial efficiency.” - 10 - Commonwealth v. Monjaras-Amaya, 163 A.3d 466, 469 (Pa. Super. 2017).

2024See, e.g., Commonwealth v. Monjaras-Amaya, 163 A.3d 466, 469 (Pa. Super. 2017). ____________________________________________ 2 Appellant’s counsel-amended PCRA petition only requested reinstatement of his “appellate rights,” and the trial court’s order only reinstated his “appellate rights” nunc pro tunc.

33
Commonwealth v. Pollardgreen
pasuperct · 2003 · cited in 4 Pennsylvania opinions naming this issue, 2006–2021
2 sentences

2021Commonwealth v. Pollard, 832 A.2d 517, 522 (Pa. Super. 2003).

2019Id. at 522 . -7 J -S70041-18 Instantly, at the guilty plea hearing on July 14, 2015, Appellant engaged in a thorough oral guilty plea colloquy.

24
Commonwealth v. Turetskygreen
pasuperct · 2007 · cited in 3 Pennsylvania opinions naming this issue, 2013–2017
2 sentences

2017The trial court may find the defendant competent to enter a plea if the "defendant comprehends the crime for which he stands accused, is able to cooperate with counsel in forming a rational defense, and has a rational and factual understanding of the proceedings against him." Commonwealth v. Willis, 68 4Petitioner was found to be competent approximately five (5) months prior to the guilty plea hearing when he underwent a mental health evaluation ordered by the Honorable Pamela Pryor Dembe on January 24, 2007. 11 A.3d 997, 1002 (Pa. Super. 2013) (citing Commonwealth v. Turetsky, 925 A.2d 876 (P

2016Weaver cannot now seek relief on grounds that contradict the statements he made under oath at the guilty plea hearing.9 Commonwealth v. Turetksy, 925 A.2d 876, 881 (Pa.Super. 2007). ____________________________________________ 8 Section 1543(b)(1.1)(i) of the Vehicle Code provides: A person who has an amount of alcohol by weight in his blood that is equal to or greater than .02% at the time of testing . . . or who refuses testing of blood or breath and who drives a motor vehicle on any highway or trafficway of this Commonwealth at a time when the person’s operating privilege is suspended or re

23
Com. v. Martinez Santiago, J.green
pasuperct · 2022 · cited in 2 Pennsylvania opinions naming this issue, 2023–2024
2 sentences

2024Sys. of PA, LLC, 252 A.3d 628 , 636 (Pa. 2021) (cleaned up) (defining “power” as “the ability of a decision-making body to order or effect a certain result”); Commonwealth v. Santiago, 270 A.3d 512, 519-20 (Pa.Super. 2022) (holding that guilty plea and resulting judgment of sentence were legal nullities because magisterial district judge lacked jurisdiction to convert the preliminary hearing into a guilty plea hearing as to the summary charges where the original felony and misdemeanor charges had not been properly -5- J-E02002-23 withdrawn).

2023See Commonwealth v. Santiago, 270 A.3d 512 , 519-20 (Pa.Super. 2022) (holding that guilty plea and resulting judgment of sentence were legal nullities because magisterial district judge lacked jurisdiction to convert the preliminary hearing into a guilty plea hearing as to the summary charges where the original felony and misdemeanor charges had not been properly withdrawn); Davis, supra at 936-37 (deeming convictions a legal nullity where magisterial district judge lacked competent jurisdiction to transform the preliminary hearing into a summary trial); Domus, supra at 636.

22
Commonwealth v. Tukhigreen
pasuperct · 2016 · cited in 2 Pennsylvania opinions naming this issue, 2021–2021
2 sentences

2021Accordingly, as this claim is waived, it is wholly frivolous.9 See Commonwealth v. Tukhi, 149 A.3d 881, 888 (Pa. Super. 2016) (“An issue that is waived is frivolous.”).

2021As noted above, in order to preserve an issue related to the validity of a guilty plea, a defendant must either object during the colloquy or otherwise raise the issue at the guilty plea hearing, sentencing hearing, or in a post-sentence motion.8 Lincoln, supra; accord Commonwealth v. Tareila, 895 A.2d 1266 , 1270 n.3 (Pa. Super. 2006); see also Pa.R.A.P. 302(a) (“Issues not raised in the lower court are waived and cannot be raised for the first time on appeal.”). ____________________________________________ 8 Indeed, “[p]ost-sentence motions for withdrawal are subject to higher scrutiny since

22
Commonwealth v. Kpougreen
pasuperct · 2016 · cited in 2 Pennsylvania opinions naming this issue, 2021–2021
2 sentences

2021As noted above, in order to preserve an issue related to the validity of a guilty plea, a defendant must either object during the colloquy or otherwise raise the issue at the guilty plea hearing, sentencing hearing or in post-sentence motions.8 Lincoln, ____________________________________________ 8 Indeed, “[p]ost-sentence motions for withdrawal are subject to higher scrutiny since courts strive to discourage the entry of guilty pleas as sentencing-testing devices.” Commonwealth v. Kpou, 153 A.3d 1020, 1023 (Pa. Super. 2016). -8- supra; accord: Commonwealth v. Tareila, 895 A.2d 1266 , 1270 n.

2021As noted above, in order to preserve an issue related to the validity of a guilty plea, a defendant must either object during the colloquy or otherwise raise the issue at the guilty plea hearing, sentencing hearing, or in a post-sentence motion.8 Lincoln, supra; accord Commonwealth v. Tareila, 895 A.2d 1266 , 1270 n.3 (Pa. Super. 2006); see also Pa.R.A.P. 302(a) (“Issues not raised in the lower court are waived and cannot be raised for the first time on appeal.”). ____________________________________________ 8 Indeed, “[p]ost-sentence motions for withdrawal are subject to higher scrutiny since

22
Commonwealth v. Colegreen
pa · 1989 · cited in 3 Pennsylvania opinions naming this issue, 1989–1996
2 sentences

1996If the court permitted withdrawal of the plea, the defendant would be allowed “to make a mockery of the guilty plea hearing process in which [the de fendant], after a full and complete colloquy, admitted his guilt.” Id. at 335 , 564 A.2d at 206 .

1996If the court permitted withdrawal of the plea, the defendant would be allowed “to make a mockery of the guilty plea hearing process in which [the de fendant], after a full and complete colloquy, admitted his guilt.” Id. at 335 , 564 A.2d at 206 .

13
Commonwealth v. Muhammadgreen
pasuperct · 2002 · cited in 2 Pennsylvania opinions naming this issue, 2019–2025
2 sentences

2025See, e.g., Commonwealth v. Muhammad, 794 A.2d 378, 384 (Pa. Super. 2002); Barnes, supra. Moreover, Appellant’s claim that he did not recall what he said at his guilty plea hearing that was inconsistent with what he stated at his June 17, 2021 hearing, does not establish that his prior plea was not done knowingly, voluntarily, and intelligently.

2019Id. - 10 - At the guilty plea hearing, the following exchange in which the court explains that Mumau could be sentenced to consecutive, maximum sentences occurred: THE COURT: Do you understand that since this plea is for an open plea, you could be sentenced to each case number to it’s maximum, one consecutive to the other; do you understand that?

12
Domus, Inc., Aplt. v. Signature Building Systemsgreen
pa · 2021 · cited in 2 Pennsylvania opinions naming this issue, 2023–2024
2 sentences

2024Sys. of PA, LLC, 252 A.3d 628 , 636 (Pa. 2021) (cleaned up) (defining “power” as “the ability of a decision-making body to order or effect a certain result”); Commonwealth v. Santiago, 270 A.3d 512, 519-20 (Pa.Super. 2022) (holding that guilty plea and resulting judgment of sentence were legal nullities because magisterial district judge lacked jurisdiction to convert the preliminary hearing into a guilty plea hearing as to the summary charges where the original felony and misdemeanor charges had not been properly -5- J-E02002-23 withdrawn).

2023See Commonwealth v. Santiago, 270 A.3d 512 , 519-20 (Pa.Super. 2022) (holding that guilty plea and resulting judgment of sentence were legal nullities because magisterial district judge lacked jurisdiction to convert the preliminary hearing into a guilty plea hearing as to the summary charges where the original felony and misdemeanor charges had not been properly withdrawn); Davis, supra at 936-37 (deeming convictions a legal nullity where magisterial district judge lacked competent jurisdiction to transform the preliminary hearing into a summary trial); Domus, supra at 636.

12
Commonwealth v. Sautergreen
pa · 1989 · cited in 2 Pennsylvania opinions naming this issue, 1993–2018
2 sentences

2018Commonwealth v. Sauter, 389 Pa.Super. 484, 487-88 , 567 A.2d 707, 708-09 (1989) and Pa.R.Crim.P. 590.

2018Commonwealth v. Sauter, 389 Pa.Super. 484, 487-88 , 567 A.2d 707, 708-09 (1989) and Pa.R.Crim.P. 590.

12
Commonwealth v. Ousleygreen
pasuperct · 2011 · cited in 2 Pennsylvania opinions naming this issue, 2015–2016
2 sentences

2016Appellant’s Brief at 2. -2- J-S38036-16 Our standard of review from the denial of post-conviction relief “is limited to examining whether the PCRA court’s determination is supported by the evidence of record and whether it is free of legal error.” Commonwealth v. Ousley, 21 A.3d 1238, 1242 (Pa.Super.2011) (citing Commonwealth v. Morales, 701 A.2d 516, 520 (Pa.1997)).

2015This claim lacks merit. -5- J-S21029-15 For ineffective assistance of counsel claims, the petitioner must establish: “(1) that the underlying claim has merit; (2) counsel had no reasonable strategic basis for his or her action or inaction; and (3) but for the errors or omissions of counsel, there is a reasonable probability that the outcome of the proceedings would have been different.” Ousley, 21 A.3d at 1244 (quoting Commonwealth v. Rivera, 10 A.3d 1276, 1279 (Pa.Super.2010)). “[C]ounsel is presumed to be effective and the burden of demonstrating ineffectiveness rests on appellant.” Id.

12
Commonwealth v. Stewartgreen
pasuperct · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
11
Commonwealth v. Mrozikgreen
pasuperct · 2019 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026See Commonwealth v. Mrozik, 213 A.3d 273 , 277 n.6 (Pa. Super. 2019) (citing (Footnote Continued Next Page) -4- 26-27.

11
Com. v. Johnson, R.green
pasuperct · 2020 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
11
Com. v. Arnold, D.green
pasuperct · 2022 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026See Pa.R.A.P. 1925(b)(4)(ii), (vii); Commonwealth v. Arnold, 284 A.3d 1262, 1278 (Pa. Super. 2022).10 ____________________________________________ 10 Even if not waived, a review of the record would reveal no basis for affording Simmons relief because at the guilty plea hearing, Simmons stipulated to the criminal complaint and affidavit of probable cause which, in relevant part, stated that officers recovered “a stolen handgun . . . in the pants of Simmons” and heroin, cocaine and marijuana in “his Nissan Altima[,]” which he had given permission to search.

11
Commonwealth v. Matthewsgreen
pasuperct · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
11
Commonwealth v. Prestongreen
pasuperct · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
2 sentences

2026Date: 7/29/2026 ____________________________________________ hearing from the [c]ourt now that he’s not getting the sweetheart deal … isn’t a ground to withdraw this.” N.T., 8/27/25, at 39; see also id. at 40 (trial court stating, “Let [Appellant] file an appeal. … He can get the transcript of the guilty plea hearing.” (emphasis added)).

2026See Preston, 904 A.2d at 7 (“When the appellant … fails to conform to the requirements of Rule 1911, any claims that cannot be resolved in the absence of the necessary transcript or transcripts must be deemed waived for the purpose of appellate review.”). 5 Appellant’s remaining claims are waived on this basis. ____________________________________________ 5 We note that during the sentencing hearing, when Appellant expressed his understanding that his plea included a negotiated sentence, the trial court stated, “I never agreed to a closed plea.

11
Commonwealth v. Wilsongreen
pasuperct · 2008 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
11
Commonwealth v. Hardy, W., Apltgreen
pa · 2025 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
11
Commonwealth v. Rushgreen
pasuperct · 2008 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
11
Commonwealth v. Jabbiegreen
pasuperct · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
11
Commonwealth v. Zeiglergreen
pasuperct · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
11
Commonwealth v. Thompsongreen
pasuperct · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
11
Com. v. Midgley, M.green
pasuperct · 2023 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
11
Commonwealth v. Grantred
pa · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
11
Commonwealth v. Poplawskigreen
pasuperct · 2004 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
11
Commonwealth v. Thomasgreen
pasuperct · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
11
Commonwealth v. Hodgesgreen
pasuperct · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
11
Commonwealth v. Brazilgreen
pa · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
11
Commonwealth v. Millergreen
pasuperct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
11
Com. v. Davis, C.green
pasuperct · 2020 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
11
Commonwealth v. Spencergreen
pasuperct · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
11
Commonwealth v. Porrecagreen
pa · 1991 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
11
Commonwealth v. Flowersgreen
pasuperct · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
11
Commonwealth v. Jacksongreen
pasuperct · 2011 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (29)

CaseCitedYears
Commonwealth v. Santiago green
pa · 2009
2 sentences

2026At the guilty plea hearing, Appellant agreed to the following factual basis: ____________________________________________ * Retired Senior Judge assigned to the Superior Court. 1 75 Pa.C.S. §§ 3733(a), 3736(a), and 1453(b)(1)(i), respectively. 2 Anders v. California, 386 U.S. 738 (1967); Commonwealth v. Santiago, 978 A.2d 349 (Pa. 2009). [O]n March 5th of 2023, [Appellant] operate[d] a motor vehicle on a public highway, specifically Smedley Street, Gramville Street, State Route 426, South Washington Street, and other roads in the area of North East in Erie County[.

2023At the close of the guilty plea hearing, the trial court ____________________________________________ 1 18 Pa.C.S.A. § 3502(a)(2). 2 18 Pa.C.S.A. § 5126(a). 3 Anders v. California, 368 U.S. 738 (1967); Commonwealth v. McClendon, 434 A.2d 1185 (Pa. 1981); Commonwealth v. Santiago, 978 A.2d 349 (Pa. 2009). 4 As discussed infra, Whitmarsh pled guilty at the above-mentioned dockets at the same hearing, was sentenced simultaneously on both, and has filed identical Anders briefs.

42023–2026
Commonwealth v. Lincoln green
pasuperct · 2013
2 sentences

2021As noted above, in order to preserve an issue related to the validity of a guilty plea, a defendant must either object during the colloquy or otherwise raise the issue at the guilty plea hearing, sentencing hearing, or in a post-sentence motion.8 Lincoln, supra; accord Commonwealth v. Tareila, 895 A.2d 1266 , 1270 n.3 (Pa. Super. 2006); see also Pa.R.A.P. 302(a) (“Issues not raised in the lower court are waived and cannot be raised for the first time on appeal.”). ____________________________________________ 8 Indeed, “[p]ost-sentence motions for withdrawal are subject to higher scrutiny since

2019Lincoln, 72 A.3d at 609-610 ; see also Commonwealth v. Tareila, 895 A.2d 1266 , 1270 n.3 (Pa. Super. 2006) (same); Pa.R.A.P. 302(a) (stating that “[i]ssues not raised in the lower court are waived and cannot be raised -8- for the first time on appeal”).

42015–2021
Anders v. California green
scotus · 1967
2 sentences

2026At the guilty plea hearing, Appellant agreed to the following factual basis: ____________________________________________ * Retired Senior Judge assigned to the Superior Court. 1 75 Pa.C.S. §§ 3733(a), 3736(a), and 1453(b)(1)(i), respectively. 2 Anders v. California, 386 U.S. 738 (1967); Commonwealth v. Santiago, 978 A.2d 349 (Pa. 2009). [O]n March 5th of 2023, [Appellant] operate[d] a motor vehicle on a public highway, specifically Smedley Street, Gramville Street, State Route 426, South Washington Street, and other roads in the area of North East in Erie County[.

2020In May 2016, Jackson entered a negotiated guilty plea to one count of possession with intent to distribute (“PWID”) Xanax and Naloxone.2 Colloquy ____________________________________________ 1 Anders v. California, 386 U.S. 738 (1967). 2 “Naloxone is an opioid antagonist that is used to temporarily reverse the effects of an opioid overdose, namely slowed or stopped breathing.” U.S. Surgeon General’s Advisory on Naloxone and Opioid Overdose, available at https://www.hhs.gov/surgeongeneral/priorities/opioids-and-addiction/ naloxone-advisory/index.html (last visited Dec. 19, 2019). for Plea of Gu

32020–2026
Commonwealth v. Finley green
pa · 1988
2 sentences

2022On September 20, 2019, Pitt filed a pro se response to the Rule 907 notice, styled as “Amended Post Conviction Relief Act Petition in Response to this Court’s 907 Notice to Dismiss” (hereinafter, “907 Response”), in which he claimed the following: 1) his guilty plea was unknowing and unintelligent because he was not informed at the guilty plea hearing that his sentence would include mandatory restitution; 2) his trial, direct appeal, and PCRA counsel were all ineffective for failing to raise this claim; 3) his trial, direct appeal, and PCRA counsel were all ineffective for failing to raise the

2018On February 7, 2018, the [c]ourt issued an Order directing [Appellant] to file a Statement of Errors Complained of on Appeal. [Appellant] filed a Concise Statement of Errors Complained of on Appeal on February 20, 2018. ____________________________________________ 2 Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988); Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (en banc). -2- J-S49007-18 [Appellant] filed a subsequent Request for Transcripts on February 23, 2018, requesting transcripts of his Guilty Plea hearing on February 17, 2014, and his Sentencing/SVP hearing on August 7, 2014.

32018–2023
Commonwealth v. McClendon green
pa · 1981
2 sentences

2023At the close of the guilty plea hearing, the trial court ____________________________________________ 1 18 Pa.C.S.A. § 3502(a)(2). 2 18 Pa.C.S.A. § 5126(a). 3 Anders v. California, 368 U.S. 738 (1967); Commonwealth v. McClendon, 434 A.2d 1185 (Pa. 1981); Commonwealth v. Santiago, 978 A.2d 349 (Pa. 2009). 4 As discussed infra, Whitmarsh pled guilty at the above-mentioned dockets at the same hearing, was sentenced simultaneously on both, and has filed identical Anders briefs.

2023At the close of the guilty plea hearing, the trial court ____________________________________________ 1 18 Pa.C.S.A. § 3502(a)(2). 2 18 Pa.C.S.A. § 5126(a). 3 Anders v. California, 368 U.S. 738 (1967); Commonwealth v. McClendon, 434 A.2d 1185 (Pa. 1981); Commonwealth v. Santiago, 978 A.2d 349 (Pa. 2009). 4 As discussed infra, Whitmarsh pled guilty at the above-mentioned dockets at the same hearing, was sentenced simultaneously on both, and has filed identical Anders briefs.

22023–2023
Commonwealth v. Turner green
pa · 1988
2 sentences

2023The PCRA court agreed, granted counsel's ____________________________________________ 2 Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988) and Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (en banc). -4- petition to withdraw, and dismissed Appellant's petition pursuant to Pa.R.Crim.P. 907.

2018On February 7, 2018, the [c]ourt issued an Order directing [Appellant] to file a Statement of Errors Complained of on Appeal. [Appellant] filed a Concise Statement of Errors Complained of on Appeal on February 20, 2018. ____________________________________________ 2 Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988); Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (en banc). -2- J-S49007-18 [Appellant] filed a subsequent Request for Transcripts on February 23, 2018, requesting transcripts of his Guilty Plea hearing on February 17, 2014, and his Sentencing/SVP hearing on August 7, 2014.

22018–2023
Commonwealth v. Muniz, J., Aplt. red
pa · 2017
2 sentences

2020Approximately four months after the guilty plea hearing, our Supreme Court decided Commonwealth v. Muniz, 164 A.3d 1189 (Pa. 2017) (plurality).

2018Appellant also referred to Commonwealth v. Muniz, 164 A.3d 1189 (Pa. 2017), and ____________________________________________ 3 At the guilty plea hearing, Appellant was incorrectly apprised that his conviction for indecent assault of a child carried a fifteen-year registration requirement under SORNA.

22018–2020
Commonwealth v. Kelly green
pasuperct · 2010
2 sentences

2019Based on the foregoing excerpts from the guilty plea hearing, it is clear that [Appellant] was aware at the time he entered his plea that he would not receive the 30-day credit for time served on this case and that the correctional institution would determine whether he was entitled to receive good time. “[A] defendant is bound by the statements he makes during his plea colloquy, and may not assert grounds for withdrawing the plea that contradict statements made when he pled.” Commonwealth v. Kelly, 5 A.3d 370 , 382 n.11 (Pa. Super. 2010). [Appellant’s] claim that counsel misled him regarding

2018That case is currently on appeal before this Court at docket number 3937 EDA of 2017. -7- J-S74010-18 statements made when he pled.” Commonwealth v. Kelly, 5 A.3d 370 , 382 n.11 (Pa. Super. 2010).

22018–2019
Commonwealth v. Lewis green
pasuperct · 1993
2 sentences

2017Commonwealth v. Lewis, 634 A.2d 633 (Pa. Super. 1993); see also, Commonwealth v. McCauley, 797 A.2d 920 (Pa. Super. 2001) (a criminal defendant is bound by the statements he makes during his plea colloquy and may not assert grounds for withdrawing the plea that contradict the statements when he pied).

2015Commonwealth v. Lewis, 634 A.2d 633 (Pa. Super. 1993).

22015–2017
Commonwealth v. Fullin green
pasuperct · 2006
2 sentences

2016See Walls, supra; Crump, supra; Fullin, supra. The record makes clear the court heard the Commonwealth’s recitation of the facts at the guilty plea hearing, which Appellant did not dispute.

2016See Walls, supra; Crump, supra; Fullin, supra; Kenner, supra. The record makes clear the court heard the Commonwealth’s recitation of the facts at the guilty plea hearing, which Appellant did not dispute.

22016–2016
Commonwealth v. Crump green
pasuperct · 2010
2 sentences

2016See Walls, supra; Crump, supra; Fullin, supra. The record makes clear the court heard the Commonwealth’s recitation of the facts at the guilty plea hearing, which Appellant did not dispute.

2016See Walls, supra; Crump, supra; Fullin, supra; Kenner, supra. The record makes clear the court heard the Commonwealth’s recitation of the facts at the guilty plea hearing, which Appellant did not dispute.

22016–2016
Commonwealth v. Leonhart green
pa · 1986
12025–2025
Commonwealth v. Barnes green
pasuperct · 1996
12025–2025
Com. v. McClendon, C. green
pasuperct · 2023
12025–2025
Commonwealth v. Johnson green
pasuperct · 2017
12023–2023
Commonwealth v. Vasquez green
pa · 2000
12022–2022
Miranda v. Arizona green
scotus · 1966
12022–2022
Com. v. Chichkin, I. yellow
pasuperct · 2020
12021–2021
Commonwealth v. Sharpe green
pasuperct · 1995
12021–2021
Commonwealth v. Wah green
pasuperct · 2012
12021–2021
Commonwealth v. Brown green
pasuperct · 2012
12021–2021
Commonwealth v. Morrison green
pasuperct · 2005
12021–2021
Mitchell v. United States green
scotus · 1999
12020–2020
Commonwealth v. Johnson green
pa · 2009
12019–2019
Commonwealth, Aplt. v. Carrasquillo, J. green
pa · 2015
12019–2019
Brady v. Maryland green
scotus · 1963
12019–2019
Commonwealth v. Barndt green
pasuperct · 2013
12019–2019
Apprendi v. New Jersey green
scotus · 2000
12018–2018
Commonwealth v. Koren green
pasuperct · 1994
12018–2018

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 9543 (12) PA § 18 Pa. Cons. Stat. § 2702 (7) PA § 42 Pa. Cons. Stat. § 9541 (7) PA § 18 Pa. Cons. Stat. § 6301 (5) PA § 42 Pa. Cons. Stat. § 9545 (5) PA § 42 Pa. Cons. Stat. § 9721 (5) PA § 42 Pa. Cons. Stat. § 9781 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TN 280 (1971–2026) IN 264 (1974–2026) IL 201 (1975–2026) GA 179 (1975–2026) MO 161 (1972–2025) PA 154 (1968–2026) OH 96 (1993–2026) IA 71 (1975–2024) MS 66 (1995–2025) TX 61 (1978–2023) WI 59 (1980–2026) DE 43 (1976–2025) LA 41 (1983–2025) NY 34 (1979–2025) MN 24 (1987–2026) CA 24 (1965–2025) MD 20 (1973–2026) SC 18 (1984–2025) AL 17 (1977–2024) MI 17 (1971–2020) OR 16 (1981–2019) ID 16 (1990–2024) VA 12 (1981–2026) CT 11 (1970–2009) MA 11 (1978–2025) NM 8 (1977–2020) FL 8 (1993–2023) WA 7 (1976–2026) KY 6 (2012–2024) CO 6 (1992–2026) NJ 6 (1978–2018) AZ 5 (1977–2022) RI 5 (1979–2013) MT 5 (2001–2015) SD 4 (1996–2014) KS 3 (2001–2026) UT 3 (1994–2008) WY 3 (1986–2018) AR 2 (2013–2015) WV 2 (1993–2002)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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