Com. v. Rickrode, W.

CourtSuperior Court of Pennsylvania
DecidedDecember 23, 2025
Docket363 MDA 2025
StatusUnpublished

This text of Com. v. Rickrode, W. (Com. v. Rickrode, W.) 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. Rickrode, W., (Pa. Ct. App. 2025).

Opinion

J-S42027-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : WYATT LEE RICKRODE : : Appellant : No. 363 MDA 2025

Appeal from the PCRA Order Entered February 25, 2025 In the Court of Common Pleas of Adams County Criminal Division at No(s): CP-01-CR-0000556-2020

BEFORE: OLSON, J., KING, J., and LANE, J.

MEMORANDUM BY KING, J.: FILED: DECEMBER 23, 2025

Appellant, Wyatt Lee Rickrode, appeals from the order entered in the

Adams County Court of Common Pleas, which denied his first petition filed

under the Post Conviction Relief Act (“PCRA”).1 We affirm.

The trial court set forth the relevant facts underlying this case as

follows:

On May 23, 2020, Jesse Carbaugh ([the victim]) and several of his acquaintances entered onto the land at 3596 Chambersburg Rd., Franklin Township, to retrieve a few large wooden poles that the Carbaugh family had previously left on the property. The Carbaughs had rented the mobile home at 3596 Chambersburg Rd. for a period and used the poles as part of a structure attached to the back of the home. The Carbaughs received permission from the landlord to return to the property to retrieve the poles.

The new tenant at 3596 Chambersburg Rd., [Appellant], ____________________________________________

1 42 Pa.C.S.A. §§ 9541-9546. J-S42027-25

despite being notified in advance that the Carbaughs would be coming to get the poles, claimed that he felt threatened by their presence from the moment that they entered the property. Appellant did not know [the victim] before [the victim] arrived at the property that day. An argument ensued between the parties as to how far into the back yard Dan Carbaugh, [the victim’s] father, could drive his truck for purposes of loading the very heavy poles.

After the verbal argument, Appellant, who was visibly agitated according to eyewitness testimony, entered his mobile home. His family and friends were inside the home and observed Appellant walk to his bedroom, grab a shotgun, load ammunition into the weapon, and walk back toward the door to leave. Some of those acquaintances attempted to prevent Appellant from leaving with the weapon, even attempting to block his exit and grabbing onto him. Nevertheless, Appellant went out of the front door, walked down the front porch steps, and turned the corner of the home to confront [the victim].

Eyewitness testimony revealed that another verbal argument between Appellant and [the victim] ensued at that point. [The victim] was unarmed. A brief moment after the argument began, Appellant discharged the firearm at [the victim] from a distance of one (1) to three (3) feet away. The gunshot hit [the victim] in the stomach. He would later die as a result of that gunshot wound. Appellant asserted that he was acting in self-defense when he shot [the victim]. Consistent with that contention, Appellant would later assert the defense of justification at trial.

(Trial Court Opinion, 7/22/22, at 1-2).

On February 11, 2022, a jury convicted Appellant of third-degree

murder. On April 21, 2022, the court sentenced Appellant to 20 to 40 years

of incarceration. On January 19, 2023, this Court affirmed Appellant’s

judgment of sentence, and our Supreme Court denied allowance of appeal.

See Commonwealth v. Rickrode, No. 746 MDA 2022 (filed Jan. 19, 2023)

-2- J-S42027-25

(unpublished memorandum), appeal denied, ___ Pa. ___, No. 75 MAL 2023

(filed Jul. 31, 2023).

On February 20, 2024, Appellant filed a timely first PCRA petition. The

court appointed counsel, who filed an amended petition on May 14, 2024. On

October 15, 2024, Appellant filed a second amended petition. On November

27, 2024, Appellant filed a third amended petition.

On December 17, 2024, the court held an evidentiary hearing. On

February 25, 2025, the court denied PCRA relief. That same day, Appellant

filed a timely notice of appeal. On March 17, 2025, the court ordered Appellant

to file a Pa.R.A.P. 1925(b) statement of errors complained of on appeal. On

April 4, 2024, Appellant filed his concise statement but did not serve it on the

PCRA court.2

On appeal, Appellant raises the following issues for our review:

I. DID THE [PCRA] COURT ERR IN DENYING APPELLANT’S POST-CONVICTION RELIEF ACT PETITION WHERE HE WAS DENIED EFFECTIVE ASSISTANCE OF COUNSEL PURSUANT TO THE SIXTH AMENDMENT OF THE UNITED STATES’

____________________________________________

2 Counsel’s failure to serve the PCRA court with a time-stamped copy of the

Pa.R.A.P. 1925(b) statement as directed amounts to per se ineffectiveness. See Commonwealth v. Burton, No. 832 EDA 2018 (Pa.Super. filed June 7, 2019) (unpublished memorandum) (remanding for appellant’s counsel to serve upon PCRA judge time-stamped copy of Rule 1925(b) statement nunc pro tunc within 10 days and for preparation of Rule 1925(a) opinion, where PCRA court had deemed all issues waived for failure to comply with Rule). See also Pa.R.A.P. 126(b) (stating we may rely on unpublished decisions of this Court filed after May 1, 2019 for their persuasive authority). In this case, however, the PCRA court was able to address Appellant’s issues on the merits. Thus, notwithstanding counsel’s ineffectiveness, we decline to remand and proceed to address the merits of the issues raised on appeal.

-3- J-S42027-25

[CONSTITUTION] AND ARTICLE I, SECTION 9 OF THE PENNSYLVANIA CONSTITUTION?

II. DID THE [PCRA] COURT ERR IN DENYING APPELLANT POST-CONVICTION RELIEF ACT PETITION WHERE HE WAS DENIED A FAIR AND IMPARTIAL TRIAL THROUGH INEFFECTIVE ASSISTANCE OF COUNSEL PURSUANT TO THE SIXTH AMENDMENT OF THE UNITED STATES’ [CONSTITUTION] AND ARTICLE I, SECTION 9 OF THE PENNSYLVANIA CONSTITUTION?

(Appellant’s Brief at 9).

“Our standard of review of the denial of a PCRA petition is limited to

examining whether the evidence of record supports the court’s determination

and whether its decision is free of legal error.” Commonwealth v. Beatty,

207 A.3d 957, 960-61 (Pa.Super. 2019), appeal denied, 655 Pa. 482, 218

A.3d 850 (2019). “[W]e review the court’s legal conclusions de novo.”

Commonwealth v. Prater, 256 A.3d 1274, 1282 (Pa.Super. 2021), appeal

denied, ___ Pa. ___, 268 A.3d 386 (2021).

Traditionally, credibility issues are resolved by the trier of fact who had the opportunity to observe the witnesses’ demeanor. A PCRA court passes on witness credibility at PCRA hearings, and its credibility determinations should be provided great deference by reviewing courts.

Beatty, supra at 961 (internal citations and quotation marks omitted).

“Counsel is presumed to have rendered effective assistance.”

Commonwealth v. Hopkins, 231 A.3d 855, 871 (Pa.Super. 2020), appeal

denied, 663 Pa. 418, 242 A.3d 908 (2020).

[T]o establish a claim of ineffective assistance of counsel, a defendant must show, by a preponderance of the evidence, ineffective assistance of counsel which, in the circumstances of the particular case, so undermined the truth-determining

-4- J-S42027-25

process that no reliable adjudication of guilt or innocence could have taken place. The burden is on the defendant to prove all three of the following prongs: (1) the underlying claim is of arguable merit; (2) that counsel had no reasonable strategic basis for his or her action or inaction; and (3) but for the errors and omissions of counsel, there is a reasonable probability that the outcome of the proceedings would have been different.

Commonwealth v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Commonwealth v. Geathers
847 A.2d 730 (Superior Court of Pennsylvania, 2004)
Commonwealth v. Lord
719 A.2d 306 (Supreme Court of Pennsylvania, 1998)
Commonwealth v. Lambert
765 A.2d 306 (Superior Court of Pennsylvania, 2000)
Commonwealth v. Pierce
645 A.2d 189 (Supreme Court of Pennsylvania, 1994)
Commonwealth v. Bibbs
970 A.2d 440 (Superior Court of Pennsylvania, 2009)
Commonwealth v. Poplawski
852 A.2d 323 (Superior Court of Pennsylvania, 2004)
Commonwealth v. Small
980 A.2d 549 (Supreme Court of Pennsylvania, 2009)
Commonwealth v. Nolen
634 A.2d 192 (Supreme Court of Pennsylvania, 1993)
Thomas v. State
634 A.2d 1 (Court of Appeals of Maryland, 1993)
Commonwealth v. Chmiel
889 A.2d 501 (Supreme Court of Pennsylvania, 2005)
Commonwealth v. Chambers
807 A.2d 872 (Supreme Court of Pennsylvania, 2002)
Commonwealth v. Mollett
5 A.3d 291 (Superior Court of Pennsylvania, 2010)
Commonwealth v. Kelley
136 A.3d 1007 (Superior Court of Pennsylvania, 2016)
Commonwealth v. Smith
167 A.3d 782 (Superior Court of Pennsylvania, 2017)
Commonwealth v. Sandusky
203 A.3d 1033 (Superior Court of Pennsylvania, 2019)
Commonwealth v. Beatty
207 A.3d 957 (Superior Court of Pennsylvania, 2019)
Commonwealth v. Roney
79 A.3d 595 (Supreme Court of Pennsylvania, 2013)
Commonwealth v. Spotz
84 A.3d 294 (Supreme Court of Pennsylvania, 2014)
Com. v. King, C.
2021 Pa. Super. 162 (Superior Court of Pennsylvania, 2021)
Com. v. Prater, W.
2021 Pa. Super. 141 (Superior Court of Pennsylvania, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
Com. v. Rickrode, W., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-rickrode-w-pasuperct-2025.