Com. v. Hoffa, K.

CourtSuperior Court of Pennsylvania
DecidedJuly 8, 2026
Docket989 MDA 2025
StatusUnpublished
AuthorDubow

This text of Com. v. Hoffa, K. (Com. v. Hoffa, K.) 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. Hoffa, K., (Pa. Ct. App. 2026).

Opinion

J-S18009-26

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : KEITH ALAN HOFFA : : Appellant : No. 989 MDA 2025

Appeal from the PCRA Order Entered June 30, 2025 In the Court of Common Pleas of Dauphin County Criminal Division at No(s): CP-22-CR-0001420-2018

BEFORE: DUBOW, J., BECK, J., and BENDER, P.J.E.

MEMORANDUM BY DUBOW, J.: FILED JULY 08, 2026

Appellant, Keith Alan Hoffa, appeals from the June 30, 2025 order

entered in the Dauphin County Court of Common Pleas dismissing his petition

filed pursuant to the Post Conviction Relief Act (“PCRA”), 42 Pa.C.S. §§ 9541-

46. After careful review, we affirm.

The relevant facts and procedural history are as follows. In 2018, the

Commonwealth charged Appellant in connection with sex-related crimes

perpetrated against seven underage victims between the ages of 8 and 16.

Appellant committed the crimes between 1996 and 2016 in Juniata and

Dauphin Counties. On May 30, 2019, Appellant filed a motion for severance

requesting that Appellant receive a separate trial for each victim. After a

hearing, the court denied Appellant’s motion.

On November 18, 2019, Appellant filed a motion for disclosure of grand

jury testimony, requesting: any transcripts of testimony of witnesses that the J-S18009-26

Commonwealth intended to call at trial, any exculpatory transcripts of

testimony, and any exculpatory physical evidence presented to the grand jury.

The court granted Appellant’s motion.

On December 9, 2019, Appellant appeared for jury selection. After more

than 30 jurors were stricken for cause, Appellant raised concerns with trial

counsel because of the opinions expressed by the stricken jurors concerning

perpetrators of sexual abuse. During a recess in selection, trial counsel

alerted the court that Appellant wished to waive his right to a jury and proceed

with a bench trial instead. Later that day, the trial court conducted an on-

the-record waiver colloquy and Appellant indicated that he wished to proceed

without a jury.

On December 11, 2019, at the conclusion of the bench trial, the court

convicted Appellant of fifteen counts including, inter alia, Rape of a Child and

Indecent Assault – Person Less than 13 Years of Age. On March 4, 2020, the

court sentenced Appellant to 63 to 126 years of incarceration. On September

21, 2021, this Court affirmed the judgment of sentence. Commonwealth v.

Hoffa, 2021 WL 4281302 (Pa. Super. filed Sept. 21, 2021) (non-precedential

memorandum), petition for allowance of appeal denied, 273 A.3d 505 (Pa.

2022).

On March 28, 2022, Appellant pro se filed a “Petition to Correct Illegal

Sentence,” which the court treated as a PCRA petition and appointed

Christopher Wilson, Esquire, as PCRA counsel. On April 27, 2023, Appellant’s

PCRA counsel requested a discovery conference, which the court held on May

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15, 2023. Following the conference, the PCRA court denied Appellant’s

request for discovery.

On June 30, 2023, Appellant filed a counseled “First Supplemental PCRA

Petition” alleging ineffective assistance of trial counsel.1 The PCRA court held

two evidentiary hearings on March 25, 2024, and September 10, 2024, at

which Appellant and his trial attorneys, Mary Klatt, Esquire, and Deanna

Muller, Esquire, testified. Following the hearings, the court denied Appellant’s

PCRA petition as meritless.

This timely appeal followed. Appellant and the PCRA court complied

with Pa.R.A.P. 1925.2

In his counseled brief, Appellant raises the following issues for our

review:

1. Whether the PCRA [c]ourt erred and failed to [] follow the authority of Commonwealth v. Callen, 198 A.3d 1149 (Pa. Super. 2018) when it concluded that trial counsel was not ineffective for failing to raise a venue/jurisdictional challenge and in determining that the matters in Juniata County and Dauphin County arose from the same criminal episode. Further, any reliance on the hearsay statement contained in the Commonwealth’s filing purporting to be coordination between the two counties, was not competent testimony, and would not cure the lack of the same criminal episode, or crime spree, failure[?]

2. Whether the PCRA [c]ourt erred when it concluded that trial counsel was not ineffective for failing to challenge and seek to ____________________________________________

1 Appellant subsequently filed two additional supplemental PCRA petitions on

August 25, 2023, and February 19, 2024. 2 In its Rule 1925(a) opinion, the PCRA court directs us to its June 30, 2025

opinion dismissing Appellant’s PCRA petition.

-3- J-S18009-26

quash the defective grand jury indictment when the Commonwealth failed to follow 42 Pa.C.S. [§] 4544 and Supreme Cour[t] authority found in Commonwealth v. Levinson, 389 A.2d 1062 (Pa. 1978)[?]

3. Whether the PCRA [c]ourt erred when it concluded that trial counsel was not ineffective for failing to explain all of 3 the rights given up, the matters that were waived, and the chances of prevailing at a jury trial versus a bench trial, along with only discussing his rights for only a 1–2-minute timeframe[?] Thus, the PCRA [c]ourt erred in failing to conclude that the advice given fell below the required standards to waive a bedrock constitutional right.

4. Whether the PCRA [c]ourt erred when it concluded that trial counsel was not ineffective for failing to obtain discoverable materials before trial involving the computer hard drive, the cell phones taken, the full grand jury transcript, and the sealed file and plea deal (and potential Brady v. Maryland, 373 U.S. 83 (1963) material) related to the disposition of [co-d]efendant Jamie Hoffa[?]

5. Whether the PCRA [c]ourt erred when it failed to conclude that trial counsel was ineffective for resting the defense case without calling a subpoenaed witness and without requested assistance from the Sheriff’s office or requesting that the case reconvene the next morning[?]

6. Whether the PCRA [c]ourt erred by failing to find that structural ineffectiveness or cumulative prejudice even if the discovery and witness issues, along with the limited preparation prior to the waiver of jury trial, standing alone did not rise to the level of prejudice and individually to warrant a new trial[?]

7. Whether the PCRA [c]ourt erred and abused discretion when it failed to find the instant case involved exceptional circumstances allowing and requiring discovery[?]

Appellant’s Br. at 3-5.

We review an order denying a petition for collateral relief to determine

whether the PCRA court's decision is supported by the evidence of record and

free of legal error. Commonwealth v. Fears, 86 A.3d 795, 803 (Pa. 2014).

-4- J-S18009-26

“This Court grants great deference to the findings of the PCRA court if the

record contains any support for those findings.” Commonwealth v.

Anderson, 995 A.2d 1184, 1189 (Pa. Super. 2010).

To prevail on a petition for PCRA relief, a petitioner must plead and

prove, by a preponderance of the evidence, that his conviction or sentence

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Commonwealth v. Fulton
830 A.2d 567 (Supreme Court of Pennsylvania, 2003)
Commonwealth v. Mallory
941 A.2d 686 (Supreme Court of Pennsylvania, 2008)
Commonwealth v. Brown
767 A.2d 576 (Superior Court of Pennsylvania, 2001)
Commonwealth v. Levinson
389 A.2d 1062 (Supreme Court of Pennsylvania, 1978)
Commonwealth v. Anderson
995 A.2d 1184 (Superior Court of Pennsylvania, 2010)
Commonwealth v. McCauley
588 A.2d 941 (Superior Court of Pennsylvania, 1991)
Commonwealth v. Frey
41 A.3d 605 (Superior Court of Pennsylvania, 2012)
Commonwealth v. Rivera
10 A.3d 1276 (Superior Court of Pennsylvania, 2010)
Commonwealth v. Witmayer
144 A.3d 939 (Superior Court of Pennsylvania, 2016)
Commonwealth v. Callen
198 A.3d 1149 (Superior Court of Pennsylvania, 2018)
Commonwealth v. Sandusky
203 A.3d 1033 (Superior Court of Pennsylvania, 2019)
Commonwealth v. Gould
912 A.2d 869 (Superior Court of Pennsylvania, 2006)
Commonwealth v. Busanet
54 A.3d 35 (Supreme Court of Pennsylvania, 2012)
Commonwealth v. Fears
86 A.3d 795 (Supreme Court of Pennsylvania, 2014)

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Com. v. Hoffa, K., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-hoffa-k-pasuperct-2026.