Com. v. King, G.

CourtSuperior Court of Pennsylvania
DecidedJuly 1, 2025
Docket2424 EDA 2024
StatusUnpublished

This text of Com. v. King, G. (Com. v. King, G.) 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. King, G., (Pa. Ct. App. 2025).

Opinion

J-S12018-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : GEORGE M. KING : : Appellant : No. 2424 EDA 2024

Appeal from the PCRA Order Entered August 14, 2024 In the Court of Common Pleas of Montgomery County Criminal Division at No(s): CP-46-CR-0007863-2018

BEFORE: STABILE, J., McLAUGHLIN, J., and BENDER, P.J.E.

MEMORANDUM BY McLAUGHLIN, J.: FILED JULY 1, 2025

George M. King appeals from the order denying his Post Conviction Relief

Act (“PCRA”) petition following an evidentiary hearing. See 42 Pa.C.S.A. §§

9541-9546. King argues his trial counsel was ineffective for failing to object

when at his sentencing hearing, the Commonwealth stated the incorrect prior

record score (“PRS”) and sentencing guidelines ranges. Because we find King

failed to establish prejudice, we affirm.

The PCRA court summarized the pertinent factual and procedural history

as follows.

[O]n July 23, 2019, [King] entered an open guilty plea to 35 counts of possession with intent to deliver controlled substances[,] conspiracy, two counts of corrupt organizations, one count of dealing in proceeds of unlawful activities, and one count of persons not to possess. (N.T., Open Guilty Plea, 7/23/19, pp. 3, 28). [King’s] guilty plea arose out of his admitted role as the hub of a drug trafficking enterprise, trafficking cocaine, heroin, methamphetamine, and other drugs. Id. at 16. J-S12018-25

A sentencing hearing was held on June 16, 2020. The Commonwealth read the guidelines into the record. (N.T., Sentencing, 6/16/20, pp. 3-5). Among the 40 counts, the Commonwealth incorrectly stated the guidelines for two counts, Count 39 and Count 40, as follows:

Count 39 is possession with intent to deliver. That is for the execution of the search warrant at his home. The [offense gravity score (“OGS”)] on that is ten for the weight of the fentanyl only. And Mr. King’s prior [PRS] on that count with the OGS of ten is REVOC[1], and the standard range there is 120 months to 120 months, plus or minus 12. Count - - I [believe] it’s Count 40, though it’s not in my sentencing memorandum, is a conspiracy to possession with intent aggregating all of the heroin deliveries. I have that as over 100 grams with an OGS of 11. Again, Mr. King’s [PRS] there is a REVOC, 120 months in the standard range, plus or minus 12.

Id. at 4-5. Defense counsel made his argument to this Court requesting an aggregate sentence “in single digits[.]” Id. at 16. The Commonwealth presented argument in support of its aggregate request of 15 to 30 years’, noting that that was just for the weight of the drugs found in his apartment and the gun. Id. at 17-18. The Commonwealth’s request did not take into account all of the drugs that [King] delivered to people [and] sold on the street. Id. at 18.

Prior to announcing the sentence, this Court placed its reasons for its sentence on the record including, inter alia, that [King] was the head of an organization that delivered thousands and thousands of bags of heroin and fentanyl to the streets of Montgomery County. Id. at 19, 20. This type of criminal conduct was significantly dangerous to society. Id. at 21. This Court also considered the pre-sentence investigation and report, his family situation and background, his drug and alcohol history, his expressions of remorse, and mitigating factors. Id. at 20-22.

This Court sentenced [King] to an aggregate of 12½ to 25 years’ imprisonment. Id. at 23. The aggregate sentence was structured by running nearly all of [King’s] sentences concurrently, with the exception of one consecutive sentence. ____________________________________________

1 “REVOC” refers to “Repeat Violent Offender Category.” See 204 Pa. Code §

303.4(a)(1).

-2- J-S12018-25

PCRA Court Op., 11/22/24, at 2-3. The court stated on the record at

sentencing that it was its intention that aggregate sentence be 12½ to 25

years. Id. at 4 (citing N.T., Sentencing, 6/16/20, at 23 (“the aggregated

sentence here [is] and my intention would be 12½ to 25 years”). King did not

file any post-sentence motions or a direct appeal.

King filed a timely PCRA petition, followed by a counseled, amended

petition, on which the court heard argument. King argued that his trial counsel

was ineffective for failing to object to the Commonwealth’s classifying him as

a REVOC for Counts 39 and 40 and presenting the wrong sentencing guidelines

ranges on those counts. He further argued that at the sentencing hearing, the

court had failed to consider the specific guidelines on each count. See N.T.,

PCRA Argument, 7/6/23, at 8. The Commonwealth conceded that the claim

had arguable merit but argued that King could not prove prejudice. It

contended that the court’s intention had been the aggregate sentence.

The court denied the petition, and King appealed. We remanded because

the court had not issued notice of its intent to dismiss the petition without an

evidentiary hearing. See Commonwealth v. King, No. 2052 EDA 2023, 2024

WL 2859470, at *3-4 (Pa.Super. filed June 6, 2024) (unpublished mem.);

Pa.R.Crim.P. 907.

On remand, the court held an evidentiary hearing. King presented the

witness certification of King’s trial counsel. Trial counsel conceded in the

certification that based on its comments at sentencing, the trial court

appeared to have intended an aggregate sentencing scheme of 12½ to 25

-3- J-S12018-25

years. He also acknowledged that because of the number of counts, it could

have achieved that scheme even if the parties had advised it of the correct

guidelines ranges:

[D]ue to the number of felony counts to which the defendant pled guilty in this case, it is possible that after employing the correct sentencing guidelines [the trial court] might have structured the sentences to still reflect an aggregate sentence of twelve and a half to twenty-five years which seemed to be his intended sentence for the reasons placed on the record at sentencing.

N.T., PCRA Hearing, 8/14/24, at 4.

Trial counsel testified and stated that at sentencing, he had focused his

argument on the aggregate sentence due to the large number of counts. Id.

at 5-6. He did not believe the court “would have departed from that number

regardless of what happened with the guidelines.” Id. at 6.

The PCRA court again denied the petition. It found that King had failed

to prove prejudice because it had intended an overarching sentencing scheme

of 12½ to 25 years:

It is true that the guidelines were incorrect. But I considered the totality of [King’s] criminal conduct and the factors under the [S]entencing [C]ode. I intended to fashion an aggregate sentence of 12 and a half to 25 years. I would have done that slightly differently if the proper guidelines had been provided to me by counsel.

There were so many counts here that I could have achieved a sentence of 12 and a half to 25 without going in the aggregated (sic) or above the guidelines for any particular count.

Therefore, I find there has been no actual prejudice. I would have imposed the same sentence. And I can do so again in a different fashion if that is what is required by the appellate court.

-4- J-S12018-25

And I do stand on the reasons I placed on the record initially for the sentence that I did impose here.

So the petition is denied.

Id. at 11-12; see also PCRA Ct. Op. at 11 (“Even if the sentencing guidelines

were set forth correctly for Count 39 and Count 40, this Court would have still

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