Com. v. Brooks, C.

CourtSuperior Court of Pennsylvania
DecidedMarch 17, 2026
Docket459 EDA 2025
StatusUnpublished
AuthorMurray

This text of Com. v. Brooks, C. (Com. v. Brooks, C.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Com. v. Brooks, C., (Pa. Ct. App. 2026).

Opinion

J-S02019-26

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : CURTIS T. BROOKS III : No. 459 EDA 2025

Appeal from the PCRA Order Entered January 9, 2025 In the Court of Common Pleas of Delaware County Criminal Division at No(s): CP-23-CR-0005968-2017

BEFORE: NICHOLS, J., MURRAY, J., and BENDER, P.J.E.

MEMORANDUM BY MURRAY, J.: FILED MARCH 17, 2026

The Commonwealth of Pennsylvania appeals from the order granting the

Post Conviction Relief Act (PCRA) 1 petition filed by the defendant, Curtis T.

Brooks, III (Brooks), vacating Brooks’s judgment of sentence, and

resentencing Brooks. After careful review, we vacate the PCRA court’s order

and reinstate Brooks’s judgment of sentence entered as part of his May 6,

2019, plea agreement.

The PCRA court described the relevant history underlying this appeal as

follows:

On August 5, 2017, [Brooks] went to the apartment of his former girlfriend, Erica Bailey [(Ms. Bailey)], who lived in Darby Borough, Delaware County, Pennsylvania. A fight broke out between [Brooks] and Ms. Bailey’s new boyfriend, Mario Garrett [(Mr.

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1 42 Pa.C.S.A. §§ 9541-9546. J-S02019-26

Garrett)]. As a result of the fight, [Brooks] stabbed and ultimately killed Mr. Garrett….

Relevant to these proceedings, on August 7, 2018, a status hearing was scheduled by the trial court. At this hearing, stand- in counsel appeared on behalf of [Brooks’s] counsel of record[, Tracie Burns, Esquire (Attorney Burns or plea counsel)]. Also on August 7, 2018, the guilty plea offer from the Commonwealth to murder of the third degree, in exchange for a sentence of 9-18 years[’ imprisonment,] expired, and [Brooks] rejected the offer. Subsequently on May 6, 2019, [Brooks], under a new negotiated offer, pleaded guilty to murder of the third degree and was sentenced … to confinement for a minimum term of 20 years to a maximum term of 40 years to be served in a State Correctional Institution. [See] May 6, 2019, Notes of Testimony []. On July 7, 2019, [Brooks] filed a pro se Notice of Appeal; on November [15], 2019, the Superior Court quashed as untimely [Brooks’s] appeal.2 [Commonwealth v. Brooks, 2151 EDA 2019 (Pa. Super. filed Nov. 15, 2019) (order).]

On May 6, 2020, [Brooks timely] filed a Petition for [PCRA] relief. 3 On June 3, 2020, [Brooks] filed an amended petition. … On September 29, 2023, November 2, 2023, and November 3, 2023, a PCRA hearing was held. …. On December 16, 2024, [the PCRA] court entered an order [granting Brooks’s petition,] and on January 9, 2025, having discovered a clerical error, [the] court entered an order making clear the [PCRA] court’s intention was to vacate [the] judgment of sentence for [Brooks’s] case involving murder and related charges, and to dismiss [Brooks’s] claims concerning the burglary case.

PCRA Court Opinion, 4/22/25, at 1-3 (punctuation modified; emphasis added;

footnote in original omitted; two footnotes added).

2 Brooks’s pro se notice of appeal, mailed from prison, was hand-dated July

8, 2019, and docketed on July 18, 2019.

3 Brooks filed his PCRA petition at two docket numbers: CP-23-CR-5968-2017 (the instant murder case) and CP-23-CR5969-2017 (a burglary case). This appeal only involves the murder case.

-2- J-S02019-26

The Commonwealth timely filed a notice of appeal. The Commonwealth

and the PCRA court have complied with Pa.R.A.P. 1925.

The Commonwealth presents the following issues:

1. Did the [PCRA] court err in concluding that plea counsel was ineffective for failing to adequately prepare stand-in counsel to represent [Brooks] at a status hearing, where counsel knew the Commonwealth’s plea offer would expire, and are the court’s factual findings [not] supported by the record?

2. Did the [PCRA] court err in concluding—for the first time in its memorandum opinion—that [Brooks] proved, by a preponderance of the evidence, that his guilty plea was not knowing, voluntary, or intelligent, and that relief for an involuntary plea could be granted through the PCRA without a finding of ineffective assistance?

3. Where the [PCRA] court found that plea counsel was ineffective during plea negotiations, did the [PCRA] court err by vacating [Brooks’s] sentence, but not his conviction, without first ordering the Commonwealth to reoffer the plea that was rejected on August 7, 2018, as required under Lafler v. Cooper, 566 U.S. 156 (2012)?

Commonwealth’s Brief at 4 (issues reordered).

Our standard of review of an order granting “relief under the PCRA calls

upon us to determine whether the determination of the PCRA court is

supported by the evidence of record and is free of legal

error.” Commonwealth v. Parker, 249 A.3d 590, 594 (Pa. Super. 2021)

(citation omitted). “[W]e defer to the factual findings of the post-conviction

court, which is tasked with hearing the evidence and assessing

credibility.” Commonwealth v. Johnson, 289 A.3d 959, 979 (Pa. 2023).

-3- J-S02019-26

Our standard of review of a PCRA court’s legal conclusions, however, is de

novo. Id.

Instantly, the PCRA court granted relief on Brooks’s claim of ineffective

assistance of Attorney Burns. When reviewing a claim of ineffective counsel,

“[c]ounsel is presumed effective, and [the PCRA petitioner] bears the burden

of proving otherwise.” Commonwealth v. Fears, 86 A.3d 795, 804 (Pa.

2014). To prevail on an ineffectiveness claim, a PCRA petitioner must

establish that

(1) the underlying claim has arguable merit; (2) no reasonable basis existed for counsel’s actions or failure to act; and (3) [appellant] suffered prejudice as a result of counsel’s error such that there is a reasonable probability that the result of the proceeding would have been different absent such error.

Id. (citations omitted). Failure to prove any prong of the test will defeat an

ineffectiveness claim, and counsel cannot be deemed ineffective for failing to

raise a meritless claim. Id.

“[C]laims of counsel’s ineffectiveness in connection with a guilty plea

will provide a basis for relief only if the ineffectiveness

caused an involuntary or unknowing plea.” Commonwealth v. Yager, 685

A.2d 1000, 1004 (Pa. Super. 1996) (en banc). The “voluntariness of [the]

plea depends on whether counsel’s advice was within the range of competence

demanded of attorneys in criminal cases.” Commonwealth v. Lynch, 820

A.2d 728, 733 (Pa. Super. 2003) (citation omitted). “The law does not require

that appellant be pleased with the outcome of his decision to enter a plea of

-4- J-S02019-26

guilty[.]” Commonwealth v. Diaz, 913 A.2d 871, 873 (Pa. Super. 2006)

(citation omitted). “All that is required is that [appellant’s] decision to plead

guilty be knowingly, voluntarily and intelligently made.” Yager, 685 A.2d at

1004 (citation omitted) (alteration in Yager).

In the context of a plea offer rejected by a defendant, to show the

requisite prejudice, the defendant “must show the outcome of the plea process

would have been different with competent advice.” Commonwealth v.

Rizor, 304 A.3d 1034, 1054 (Pa. 2023) (citing Lafler, 566 U.S. at 1054).

Where ineffective advice led to the rejection of a plea offer,

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Related

Lafler v. Cooper
132 S. Ct. 1376 (Supreme Court, 2012)
Commonwealth v. Diaz
913 A.2d 871 (Superior Court of Pennsylvania, 2006)
Commonwealth v. Lynch
820 A.2d 728 (Superior Court of Pennsylvania, 2003)
Commonwealth v. Yager
685 A.2d 1000 (Superior Court of Pennsylvania, 1996)
Commonwealth v. Fears
86 A.3d 795 (Supreme Court of Pennsylvania, 2014)
Com. v. Parker, A.
2021 Pa. Super. 61 (Superior Court of Pennsylvania, 2021)

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Bluebook (online)
Com. v. Brooks, C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-brooks-c-pasuperct-2026.