Pennsylvania v. McGee (majority)
Annotate this CaseThe Pennsylvania Supreme Court granted appeal in this matter to consider whether the Superior Court erred in holding that a trial court lacked jurisdiction to correct a patent and obvious error in a sentencing order when the defendant’s request for correction was filed outside the time limitations of the Post Conviction Relief Act (“PCRA”). In November 1994, Appellant Rodney McGee fatally assaulted Barry Williams. In 1996, Appellant entered into a negotiated guilty plea multiple accounts for acts against multiple people; court stated that Appellant’s aggregate sentence for all of the offenses was 32 1⁄2 to 65 years. On the same day that Appellant entered his plea and the trial court orally imposed the above sentence, the trial court issued a three-page typed document titled “Order” (“typed sentencing order”) that was inconsistent with what the court orally imposed on the record. Decades later, on June 3, 2020, Appellant filed a pro se PCRA petition, and counsel was appointed. On August 5, 2020, Appellant filed a “Motion to Correct Illegal Sentence” arguing that there was an obvious incompatibility between the two orders. Finding that the orders in question were “patently erroneous” and “contrary to common sense,” the trial court concluded that amendment of the orders was proper, as the time limits of the PCRA did not apply. The Commonwealth appealed the trial court’s decision to the Superior Court, asserting that the trial court did not have jurisdiction to entertain Appellant’s Motion because the underlying claim was cognizable under the PCRA, and had been filed outside the PCRA’s jurisdictional time constraints. In a unanimous memorandum opinion, the Superior Court reversed. The Pennsylvania Supreme Court affirmed, finding no "patent and obvious error" in the trial court's sentencing orders. The Court did not reach the question of whether a trial court’s inherent authority to correct patent and obvious errors in the record is subject to the time limitations of the PCRA.
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