Com. v. Leonard, E.

Superior Court of Pennsylvania·Decided August 27, 2026·No. 50 MDA 2026·Unpublished·Beck

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

:

v. :

:

:

ERNEST LORENZO LEONARD SR. :

:

Appellant : No. 50 MDA 2026

Appeal from the PCRA Order Entered December 29, 2025 In the Court of Common Pleas of Lycoming County Criminal Division at No(s): CP-41-CR-0001197-2020

BEFORE: DUBOW, J., BECK, J., and BENDER, P.J.E. MEMORANDUM BY BECK, J.: FILED: AUGUST 27, 2026 Ernest Lorenzo Leonard, Sr. (“Leonard”) appeals from the order entered by the Lycoming County Court of Common Pleas dismissing his first petition filed pursuant to the Post Conviction Relief Act (“PCRA”).1 Leonard argues his appellate counsel was ineffective for failing to properly preserve his claims on direct appeal. As we conclude his claims have no merit, we affirm.

In August 2020, the Commonwealth charged Leonard with two counts each of rape of a mentally disabled person, involuntary deviate sexual intercourse (“IDSI”) of a mentally disabled person, sexual assault, and aggravated indecent assault of a mentally disabled person, arising out of reports that he had sexually assaulted thirty-six-year-old A.W., who has a

1 42 Pa.C.S. §§ 9541-9546.

Down Syndrome diagnosis. On May 11, 2023, he filed a motion to dismiss pursuant to Pa.R.Crim.P. 600. The trial court denied Leonard’s Rule 600 motion. The case proceeded to a jury trial. Following trial, the jury convicted Leonard on all counts. The trial court then sentenced Leonard to an aggregate sentence of eight years to sixteen years of incarceration.2 Leonard then filed a timely post-sentence motion, which the court denied.

Leonard appealed, raising claims that the trial court erred in denying his Rule 600 motion, the evidence was insufficient to support his convictions, and the sentence was manifestly excessive. This Court affirmed the judgment of sentence. See Commonwealth v. Leonard, 331 A.3d 604 (Pa. Super. Nov. 4, 2024) (non-precedential decision).

On his Rule 600 claim, this Court found the trial court did not abuse its discretion in denying Leonard’s motion. Id. at **2-4. We observed that Leonard failed to provide an accounting of the time delays at issue in the case. Id. at *3. Nevertheless, we found support for the trial court’s findings that the relevant periods of delay were attributable to the defense or court scheduling, and the Commonwealth was prepared to proceed with trial. Id. at *4. Thus, the Court concluded that the jury trial was scheduled within the

2 The trial court imposed consecutive prison terms of four to eight years for

the rape convictions and concurrent prison terms of three to six years for the sexual assault convictions. The trial court found that the IDSI convictions merged for purposes of sentencing and imposed no further penalty on the aggravated indecent assault convictions.

adjusted run date. Id. Regarding his sufficiency of the evidence claim, this Court found the argument section of the brief was woefully inadequate, as counsel failed to identify which elements of each offense were being challenged, thus waiving the claim. Id. at *5. As to his discretionary aspects of sentencing claim, this was also found to be waived because Leonard failed to include a Rule 2119(f) statement in his brief, and the Commonwealth objected. Id.

On February 10, 2025, Leonard filed a timely pro se PCRA petition. The PCRA court appointed counsel, who filed an amended petition asserting appellate counsel rendered ineffective assistance by failing to properly preserve his sufficiency claim such that it deprived Leonard meaningful review of the evidence presented at trial. Leonard further contended that he had no claims reviewed on appeal as a result of appellate counsel’s ineffectiveness, and a reinstatement of his appellate rights was therefore warranted.

On December 2, 2025, the PCRA court filed a Pa.R.Crim.P. 907 notice of intent to dismiss Leonard’s PCRA petition without a hearing. Subsequently, the PCRA court dismissed the petition. Leonard filed a notice of appeal and concise statement of matters complained of on appeal.

He raises the following issues for our review:

1. [] Leonard is able to demonstrate that a challenge to the sufficiency of the evidence in his case had merit sufficiently to warrant reinstatement of his right to file Post Sentence Motions and a direct appeal with the Superior Court of Pennsylvania to obtain appellate review of his challenge to the Commonwealth’s evidence against him.

2. [] Leonard was denied his Sixth Amendment right to the effective assistance of counsel on appeal due to appellate counsel’s failure to put forth an appeal that offered any meaningful review of the issues and he is entitled to reinstatement of his right to file an effective Post Sentence Motion and direct appeal with the Superior Court of Pennsylvania.

Leonard’s Brief at 4 (issues reordered).

Standard of Review

“This Court’s standard of review regarding a PCRA court’s denial of a PCRA petition is whether the PCRA court’s decision is supported by the evidence of record and is free of legal error.” Id. “With respect to the PCRA court’s legal conclusions, we apply a de novo standard of review.” Commonwealth v. Lopez, 249 A.3d 93, 998 (Pa. 2021) (citation omitted).

As each of Leonard’s claims relate to appellate counsel’s ineffectiveness, we note that “[a] court’s review of a claim of ineffective assistance of counsel begins with the strong presumption that counsel was effective.” Commonwealth v. Pacheco, 340 A.3d 1038, 1041 (Pa. Super. 2025). To overcome this presumption, a PCRA petitioner must plead and prove, by a preponderance of evidence, that “(1) The underlying claim has arguable merit; (2) counsel had no reasonable basis for his or her action or inaction; and (3) the petitioner suffered prejudice as a result of counsel’s action or inaction.” Commonwealth v. Felix, 303 A.3d 816, 819 (Pa. Super. 2023) (citations and quotation marks omitted). “The failure to satisfy any one of the

ineffectiveness prongs precludes relief.” Commonwealth v. Drayton, 313 A.3d 954, 960 (Pa. 2024) (citation omitted).

Sufficiency of the Evidence Addressing Leonard’s second issue first, he claims his appellate counsel was ineffective because he did not preserve his claim that the evidence was insufficient to support his convictions. Leonard’s Brief at 19. Leonard argues that appellate counsel failed to adequately raise, preserve, and argue his sufficiency claim on appeal, and did so without any reasonable strategic basis. Id. at 19, 22. Noting that he was convicted of numerous offenses that require proof of sexual conduct with a person who suffers from a mental disability, and this element is material to the offenses charged, Leonard contends the Commonwealth failed to offer evidence that A.W.’s mental condition resulted in her being incapable of consenting to sexual contact. Id. at 20, 21. Leonard acknowledges that the Commonwealth offered evidence establishing that A.W. had a mental disability, but distinguishes that from the Commonwealth proving that her mental disability caused her to be incapable of consent. Id. at 22. Leonard points to the testimony of Commonwealth witness Dr. Richard Dowell and argues that he incorrectly assumed that because A.W. had a mental age that placed her below the age of consent under Pennsylvania law, she was per se unable to consent to sexual contact. Id. Finally, he argues his counsel’s failure to preserve this claim prejudiced him by preventing his constitutional right to appellate review to evaluate the sufficiency of the

Commonwealth’s proof. Id. at 22-23. Leonard seeks reinstatement of his post-sentence motion and direct appeal rights. Id. at 23.

Our Court’s standard of review of a challenge to the sufficiency of the evidence is well settled:

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