Com. v. Holley, J.

CourtSuperior Court of Pennsylvania
DecidedFebruary 3, 2025
Docket3130 EDA 2023
StatusUnpublished

This text of Com. v. Holley, J. (Com. v. Holley, J.) 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. Holley, J., (Pa. Ct. App. 2025).

Opinion

J-S38006-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : JAMES HOLLEY : : Appellant : No. 3130 EDA 2023

Appeal from the Judgment of Sentence Entered November 17, 2023 In the Court of Common Pleas of Philadelphia County Criminal Division at No: CP-51-CR-0006143-2013

BEFORE: STABILE, J., BECK, J., and STEVENS, P.J.E.*

MEMORANDUM BY STABILE, J.: FILED FEBRUARY 3, 2025

Appellant, James Holley, appeals from the modified judgment of

sentence imposed on November 17, 2023, by the Court of Common Pleas of

Philadelphia County (trial court). He challenges the trial court’s authority to

modify his sentence beyond the 30-day period set forth in 42 Pa.C.S.A. §

5505, as well as the legality of the modified sentence. Upon review, we find

merit in the claim that part of the modified sentence is illegal, requiring us to

vacate the judgment of sentence, and remand the case for further

proceedings.

The trial court aptly summarized the factual and procedural history of

this case as follows:

On August 20, 2013, [Appellant] entered a negotiated guilty plea to aggravated indecent assault of a child, graded as a felony of ____________________________________________

* Former Justice specially assigned to the Superior Court. J-S38006-24

the first degree, and [sexual abuse of children], graded as a felony of the second degree. As part of the negotiated guilty plea, [Appellant] specifically agreed to a sentence of 7 ½ to 20 years of incarceration for aggravated indecent assault of a child, to be followed by 10 years of state-supervised sex offender probation. The [trial court] accepted [Appellant’s] plea as knowingly and voluntarily tendered, and deferred sentencing pending a Megan’s Law assessment by the Sexual Offender Assessment Board (“SOAB”).

On December 5, 2013, [Appellant] appeared for sentencing, at which time the [trial court] imposed the negotiated sentence of 7 ½ to 20 years of incarceration, followed by 10 years of state- supervised sex offender probation. (N.T. 12/05/13 at 4). [Appellant] did not file a motion for reconsideration of sentence or a direct appeal.

On April 19, 2023, the Pennsylvania Department of Corrections inadvertently released [Appellant] from prison based on the mistaken belief that he had maxed out the incarceration portion of his sentence.4

4 [Appellant’s] written sentencing order erroneously indicated a sentence of 7 ½ to 10 years, which not only is an illegal sentence, but conflicted with the [trial court’s] unambiguous oral sentence on the record, as well as the written guilty plea forms and secure docket entries.

The matter came before the [trial court] on May 2, 2023, following the state parole/probation agent’s request for GPS monitoring of [Appellant] and implementation of sex offender conditions. In the interim, there was an alleged violation by [Appellant], which brought him before the [trial court] – at which time it became apparent to the [trial court] that the written sentencing order contained the erroneous, illegal sentence of 7 ½ to 10 years.

On November 17, 2023, the [trial court] held a hearing on the matter, and following argument by the parties, found that the 7 ½-to-10-year sentence in the written order was a patent mistake in light of the record:

THE COURT: . . . I find that the seven and a half to ten years was a patent mistake in the sentencing

-2- J-S38006-24

order and I’m going to sentence [Appellant] to the sentence that was agreed upon and was negotiated of seven and a half to 20 years on the aggravated indecent assault of a child, followed by ten years of state sex offender probation.

(N.T. 11/17/23 at 16-17).

Trial Court Opinion, 6/29/24, at 1-2 (some footnotes omitted). This appeal

followed. Both the trial court and Appellant have complied with Pa.R.A.P.

1925. Appellant raises four related issues for our review:

Did the trial court err when it amended [Appellant’s] sentence and increased his maximum sentence of incarceration from ten to twenty years because: (1) the written sentencing order controls, (2) the increase in sentence violated the prohibition against double jeopardy, (3) the trial court lacked jurisdiction and (4) the new sentence was illegal?

Appellant’s Brief, at 3.

We start with Appellant’s claim that the trial court lacked jurisdiction to

modify his sentence beyond the 30-day period prescribed by Section 5505.

See id. at 24-26. A question regarding the power of a trial court to correct

an alleged sentencing error presents a pure question of law; thus, our scope

of review is plenary, and our standard of review is de novo. Commonwealth

v. Borrin, 12 A.3d 466, 471 (Pa. Super. 2011) (en banc).

Generally, a trial court may only modify or rescind an order within 30

days after its entry, unless an appeal has been filed sooner. 42 Pa.C.S.A. §

5505. After that point, the trial court loses jurisdiction over the case. See

Commonwealth v. Holmes, 933 A.2d 57, 65 (Pa. 2007). However, it is

well-settled in Pennsylvania that a trial court has inherent, common-law

-3- J-S38006-24

authority to correct clear clerical errors in its orders. See id. A trial court

maintains this authority even after the expiration of the 30-day period set

forth in Section 5505. Id. Nevertheless, our Supreme Court has cautioned:

This exception to the general rule of Section 5505 cannot expand to swallow the rule. In applying the exception to the cases at bar, we note that it is the obviousness of the illegality, rather than the illegality itself, that triggers the court’s inherent power. Not all illegal sentences will be amenable to correction as patent errors. Moreover, the inherent power to correct errors does not extend to reconsideration of a court’s exercise of sentencing discretion. A court may not vacate a sentencing order merely because it later considers a sentence too harsh or lenient.

Id. at 66-67.

In Holmes, our Supreme Court considered two companion cases –

Commonwealth v. Holmes, 837 A.2d 501 (Pa. Super. 2003) and

Commonwealth v. Whitfield, 833 A.2d 1152 (Pa. Super. 2003) – to

determine whether a trial court had inherent jurisdiction to modify or rescind

an illegal order absent statutory jurisdiction under Section 5505. Id. at 58.

In Holmes, the defendant violated his parole, requiring him to serve the

balance of the original sentence.1 Id. at 59. The trial court, however,

sentenced him as if he had violated probation and imposed a new sentence.

Id. The trial court realized its mistake more than 30 days after its imposition

and sua sponte vacated the sentence. Id. This Court reversed, concluding

____________________________________________

1 “If the offender’s parole is revoked, the offender shall be recommitted to serve the remainder of the term which the offender would have been compelled to serve had the parole not been granted[.]” 61 Pa.C.S.A. § 6138(a)(2).

-4- J-S38006-24

that the mistake was not patent and obvious and “the sentence was not

facially self-contradictory or irreconcilable nor did it contain a clerical error.”

Id. at 60-61.

In Whitfield, the defendant received a sentence of incarceration, but

no probation. Id. at 62. The trial court subsequently revoked his “probation”

and imposed a new sentence. Id. at 63.

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Related

United States v. DiFrancesco
449 U.S. 117 (Supreme Court, 1980)
Commonwealth v. Decker
664 A.2d 1028 (Superior Court of Pennsylvania, 1995)
Commonwealth v. Holmes
837 A.2d 501 (Superior Court of Pennsylvania, 2003)
Commonwealth v. Jones
554 A.2d 50 (Supreme Court of Pennsylvania, 1989)
Commonwealth v. Holmes
933 A.2d 57 (Supreme Court of Pennsylvania, 2007)
Commonwealth v. Quinlan
639 A.2d 1235 (Superior Court of Pennsylvania, 1994)
Commonwealth v. Jackson
30 A.3d 516 (Superior Court of Pennsylvania, 2011)
Commonwealth v. Sojourner
518 A.2d 1145 (Supreme Court of Pennsylvania, 1986)
Commonwealth v. Foster
17 A.3d 332 (Supreme Court of Pennsylvania, 2011)
Commonwealth v. Borrin
12 A.3d 466 (Superior Court of Pennsylvania, 2011)
Commonwealth v. Ali
197 A.3d 742 (Superior Court of Pennsylvania, 2018)
Commonwealth v. Whiteman
204 A.3d 448 (Superior Court of Pennsylvania, 2019)
Commonwealth v. Harrison
661 A.2d 6 (Superior Court of Pennsylvania, 1995)

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Bluebook (online)
Com. v. Holley, J., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-holley-j-pasuperct-2025.