Shotts v. Wetzel, No. 11-3670 (3d Cir. 2013)
Annotate this Case
In 1999, Shotts was charged with a string of burglaries. Following his arrest, Shotts offered to assist in an investigation into corruption at the county prison and the District Attorney helped secure Shotts’ release on bail. Once released, Shotts engaged in another crime spree and was charged with burglary, theft, criminal mischief, criminal conspiracy, receiving stolen property, passing bad checks, criminal trespass, aggravated assault, simple assault, reckless endangerment of another person, driving under the influence of alcohol, and with three probation violations. Because Shotts had made confessions, his attorney pursued a plea deal, but did not request discovery of police records. The Commonwealth offered a plea deal with a sentence of 10 to 20 years’ imprisonment. The judge commented that the sentence seemed high, given Shotts’ assistance with the corruption investigation. Shotts rejected the deal and entered a general guilty plea, confirming that his lawyer had explained the maximum sentences. Despite evidence of Shotts’ cooperation and his earlier statement, the judge sentenced Shotts to 30½ to 133 years. Following state collateral review, during which Shotts had five different lawyers, he filed a federal habeas corpus petition, claiming that his first attorney rendered ineffective assistance. The district court dismissed the claim as procedurally defaulted. The Third Circuit affirmed on the merits, but stated that the Pennsylvania Superior Court’s determination that Shotts’ claim was defaulted because he failed to raise it when first represented by new counsel was “an exorbitant application of an otherwise independent and adequate state rule” that cannot bar federal review.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.