Com. v. Knecht, M.

CourtSuperior Court of Pennsylvania
DecidedMarch 13, 2017
DocketCom. v. Knecht, M. No. 385 EDA 2016
StatusUnpublished

This text of Com. v. Knecht, M. (Com. v. Knecht, M.) 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. Knecht, M., (Pa. Ct. App. 2017).

Opinion

J-S81019-16

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA IN THE SUPERIOR COURT OF PENNSYLVANIA Appellee

v.

MARTIN LOUIS KNECHT

Appellant No. 385 EDA 2016

Appeal from the PCRA Order February 1, 2016 In the Court of Common Pleas of Chester County Criminal Division at No(s): CP-15-CR-0000302-1977 CP-15-CR-0000303-1977

BEFORE: BOWES, J., MOULTON, J., and STEVENS, P.J.E.*

MEMORANDUM BY MOULTON, J.: FILED MARCH 13, 2017

Martin Louis Knecht appeals from the February 1, 2016 order of the

Chester County Court of Common Pleas granting partial relief on his petition

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

9546. Knecht, who had been sentenced to a mandatory sentence of life

without parole, sought relief pursuant to Miller v. Alabama, 132 S.Ct. 2455

(2012), which held that the imposition of such sentences for juvenile

offenders was unconstitutional. Without conducting a resentencing hearing

or imposing a minimum sentence, the trial court “[c]orrected” Knecht’s

judgment of sentence to reflect that he was sentenced to “life in prison, with

____________________________________________

* Former Justice specially assigned to the Superior Court. J-S81019-16

the possibility of parole.”1 Order, 2/15/16, at 1. Based on settled precedent

from our Supreme Court, we reverse the order, vacate the judgment of

sentence, and remand for the trial court to conduct a resentencing hearing

pursuant to Miller and Commonwealth v. Batts, 66 A.3d 286 (Pa. 2013).

On July 2, 1977, a jury convicted Knecht of second-degree murder,

robbery, theft by unlawful taking or disposition, and criminal conspiracy.2

On July 21, 1981, the trial court sentenced Knecht, who was 16 years old at

the time of the offense, to life imprisonment without the possibility of parole

for the second-degree-murder conviction and concurrent sentences of 10 to

20 years’ imprisonment for the robbery conviction and 5 to 10 years’

imprisonment for the conspiracy conviction. On June 29, 1984, this Court

affirmed the judgment of sentence.

Knecht filed unsuccessful post-conviction petitions in 1985, 1989,

1997, and 2010. On July 20, 2012, Knecht filed a pro se PCRA petition

arguing that his sentence of life imprisonment without the possibility of

parole was unconstitutional pursuant to Miller. On July 31, 2012, the trial

court issued an order stating its intention to grant the PCRA petition, vacate

1 The original record contains only documents filed on or after January 27, 2016 – that is, the consolidated motion to vacate stay, to vacate unconstitutional sentence, and for bail pending litigation, and later documents. We have gathered additional information and dates from the docket and a prior opinion from this Court. 2 18 Pa.C.S. §§ 2502(b), 3701, 3921, and 903, respectively.

-2- J-S81019-16

the sentence of life imprisonment without the possibility of parole, and

impose a sentence of life imprisonment with the possibility of parole. The

Commonwealth requested a stay or an extension of time to answer the PCRA

petition. On September 17, 2012, the PCRA court entered a stay “pending

the decision of the Pennsylvania Supreme Court in the cases of

Commonwealth v. Batts[3] and Commonwealth v. Cunningham,[4]

argued on September 12, 2012.”

On October 30, 2013, the Pennsylvania Supreme Court issued its

decision in Commonwealth v. Cunningham, 81 A.3d 1, 10-11 (Pa. 2013),

holding that Miller did not apply retroactively to cases on collateral review.

Neither Knecht, the Commonwealth, nor the PCRA court took steps to

address the stay following the issuance of the Cunningham decision. On

January 25, 2016, the United States Supreme Court issued its decision in

Montgomery v. Louisiana, 136 S.Ct. 718 (2016), which held that Miller

applied retroactively to cases that were final at the time Miller was decided.

On January 27, 2016, Knecht filed a consolidated motion to vacate

stay, to vacate unconstitutional sentence, and for bail pending litigation. On

February 1, 2016, the PCRA court issued an order “correct[ing]” Knecht’s

3 Commonwealth v. Batts, 981 A.2d 1283 (Pa. 2009) (granting petition for allowance of appeal). 4 Commonwealth v. Cunningham, 51 A.3d 178 (Pa. 2012) (granting petition for allowance of appeal).

-3- J-S81019-16

sentence to reflect that he was now sentenced to “life in prison, with the

possibility of parole.” Order, 2/15/16, at 1. The order, which did not include

a minimum sentence, further stated that Knecht “may file an application for

parole with the Pennsylvania Board of Probation and Parole.” Id.

On February 2, 2016, Knecht filed a timely notice of appeal. Knecht

raises the following issues on appeal:

1. Did the lower court err in acting without a hearing and without providing an opportunity for argument, allocution and the presentation of evidence when the court purported to “clarify” an unconstitutional sentence in a way not authorized by law?

2. Did the lower court usurp the legislative function and rewrite sentencing provisions in “clarifying” a sentence in a way not authorized by law, and in derogation of clear legislative intent, when it purported to make defendant eligible for parole?

3. Did the lower court err in concluding that it had judicial authority to grant the Parole Board discretionary authority to release on parole an inmate who is serving life imprisonment, and in purporting to make appellant eligible for parole, where existing Pennsylvania statutes prohibit the grant of parole to a person serving a life-sentence?

Knecht’s Br. at 4. Because Knecht’s issues are related, we will address his

arguments together.

Knecht’s arguments, while not lining up neatly with his statement of

issues, are essentially twofold. He first alleges a process error – he was

wrongly denied a resentencing hearing required by controlling authority in

both the United States Supreme Court and our Supreme Court. Second, he

alleges a substantive error – because the statute under which he was

-4- J-S81019-16

sentenced for second-decree murder is unconstitutional, and because there

is no other valid statute on which to base this aspect of his sentence, he

should be released forthwith. As set forth more fully below, we agree with

Knecht’s first claim, and thus remand for a resentencing hearing, but

disagree with his second claim.

As to process, Miller and Batts provide that juvenile offenders serving

an unconstitutional sentence of life without parole are entitled to a

resentencing hearing at which the sentencing court must take into account a

list of age-related factors, set forth in Miller, designed to insure that each

offender receives an appropriately individualized sentence. Accordingly,

Knecht correctly argues that the trial court erred by “correcting” his

sentence without such a hearing. Batts, 66 A.3d at 297 (finding appropriate

remedy for a juvenile defendant who was sentenced to life imprisonment

without possibility of parole is remand for resentencing where trial court will

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Related

Commonwealth v. Batts
981 A.2d 1283 (Supreme Court of Pennsylvania, 2009)
Miller v. Alabama
132 S. Ct. 2455 (Supreme Court, 2012)
Montgomery v. Louisiana
577 U.S. 190 (Supreme Court, 2016)
Commonwealth v. Mitchell
135 A.3d 1097 (Superior Court of Pennsylvania, 2016)
Commonwealth v. Cunningham
51 A.3d 178 (Supreme Court of Pennsylvania, 2012)
Commonwealth v. Batts
66 A.3d 286 (Supreme Court of Pennsylvania, 2013)
Commonwealth v. Cunningham
81 A.3d 1 (Supreme Court of Pennsylvania, 2013)

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Com. v. Knecht, M., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-knecht-m-pasuperct-2017.