Com. v. Ritchie, C.

CourtSuperior Court of Pennsylvania
DecidedFebruary 13, 2025
Docket275 WDA 2024
StatusUnpublished

This text of Com. v. Ritchie, C. (Com. v. Ritchie, C.) 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. Ritchie, C., (Pa. Ct. App. 2025).

Opinion

J-A29045-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : CAMERON RITCHIE : : Appellant : No. 275 WDA 2024

Appeal from the PCRA Order Entered February 2, 2024 In the Court of Common Pleas of Allegheny County Criminal Division at No(s): CP-02-CR-0005380-2020

BEFORE: OLSON, J., LANE, J., and BENDER, P.J.E.

MEMORANDUM BY BENDER, P.J.E.: FILED: FEBRUARY 13, 2025

Appellant, Cameron Ritchie, appeals from the post-conviction court’s

order denying his timely-filed petition under the Post Conviction Relief Act

(PCRA), 42 Pa.C.S. §§ 9541-9546. Appellant raises one claim of trial counsel’s

ineffectiveness. After careful review, we affirm.

The facts underlying Appellant’s convictions are not germane to our

disposition of the issue he raises herein. We need only note that, on

September 27, 2021, Appellant entered a guilty plea to strangulation and

simple assault. That same day, he was sentenced to an aggregate term of

three to ten years’ incarceration. He timely appealed, but then later filed a

praecipe to discontinue that appeal.

On January 3, 2023, Appellant filed a timely, pro se PCRA petition.

Counsel was appointed and filed an amended petition on his behalf. After the

Commonwealth filed a response, the PCRA court issued a Pa.R.Crim.P. 907 J-A29045-24

notice of its intent to dismiss Appellant’s petition without a hearing. Appellant

filed a response to the Rule 907 notice, but on February 2, 2024, the court

dismissed his petition.

Appellant filed a timely notice of appeal, and he and the court complied

with Pa.R.A.P. 1925. Herein, Appellant states one issue for our review: “Did

the PCRA [c]ourt err in determining that [trial] counsel was not ineffective for

failing to call witnesses to testify about [Appellant’s] specific circumstances at

the time of sentencing[?]” Appellant’s Brief at 4.

“This Court’s standard of review from the grant or denial of post-

conviction relief is limited to examining whether the lower court’s

determination is supported by the evidence of record and whether it is free of

legal error.” Commonwealth v. Morales, 701 A.2d 516, 520 (Pa. 1997)

(citing Commonwealth v. Travaglia, 661 A.2d 352, 356 n.4 (Pa. 1995)).

Where, as here, a petitioner claims that he received ineffective assistance of

counsel, our Supreme Court has stated that:

[A] PCRA petitioner will be granted relief only when he proves, by a preponderance of the evidence, that his conviction or sentence resulted from the “[i]neffective assistance of counsel which, in the circumstances of the particular case, so undermined the truth- determining process that no reliable adjudication of guilt or innocence could have taken place.” Generally, counsel’s performance is presumed to be constitutionally adequate, and counsel will only be deemed ineffective upon a sufficient showing by the petitioner. To obtain relief, a petitioner must demonstrate that counsel’s performance was deficient and that the deficiency prejudiced the petitioner. A petitioner establishes prejudice when he demonstrates “that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” … [A] properly pled claim of

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ineffectiveness posits that: (1) the underlying legal issue has arguable merit; (2) counsel’s actions lacked an objective reasonable basis; and (3) actual prejudice befell the petitioner from counsel’s act or omission.

Commonwealth v. Johnson, 966 A.2d 523, 532-33 (Pa. 2009) (citations

omitted).

Here, Appellant claims that his trial counsel was ineffective for not

calling witnesses at his sentencing hearing “to inform the [c]ourt about

relevant information regarding therapy he attended, classes he successfully

completed, and other positive changes [Appellant] made in his life.”

Appellant’s Brief at 13. Appellant avers that his claim has arguable merit

because “[a]ny information that would impact the sentence should have been

presented to the [c]ourt.” Id. at 15. In regard to the reasonable-basis prong,

Appellant claims that his trial “counsel alluded to the witnesses and the

information they would have provided[,]” showing that counsel “was aware

the information was important for sentencing” and could have had no

reasonable basis for not calling these witnesses. Id. Finally, with respect to

prejudice, Appellant states that these “uncalled witnesses would have

provided beneficial testimony” and, “[i]f the [c]ourt would have heard directly

from people who were familiar with [Appellant’s] therapy and attempts to

better himself, this would have impacted the sentence imposed.” Id. at 14.

He insists that “counsel’s failure to call witnesses to testify at sentencing was

detrimental” because “[t]he [c]ourt imposed [his] sentence without hearing

from individuals who had pertinent information for the court to consider.

[Appellant] believes the [c]ourt would have imposed a lesser sentence, if

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those witnesses had been called to provide relevant information to the

[c]ourt.” Id.

Appellant’s argument is unconvincing. Initially, we recognize:

[W]hen raising a claim of ineffectiveness for the failure to call a potential witness, a petitioner satisfies the performance and prejudice requirements of the Strickland v. Washington, 466 U.S. 668 … (1984)[,] test by establishing that: (1) the witness existed; (2) the witness was available to testify for the defense; (3) counsel knew of, or should have known of, the existence of the witness; (4) the witness was willing to testify for the defense; and (5) the absence of the testimony of the witness was so prejudicial as to have denied the defendant a fair trial….

Commonwealth v. Sneed, 45 A.3d 1096, 1108–09 (Pa. 2012). “To demonstrate Strickland prejudice, a petitioner must show how the uncalled witnesses’ testimony would have been beneficial under the circumstances of the case.” Sneed, 45 A.3d at 1109. Counsel will not be found ineffective for failing to call a witness “unless the petitioner can show that the witness’s testimony would have been helpful to the defense. A failure to call a witness is not per se ineffective assistance of counsel for such decision usually involves matters of trial strategy.” Id. (internal quotation marks and citations omitted).

Commonwealth v. Matias, 63 A.3d 807, 810–11 (Pa. Super. 2013) (some

internal brackets omitted).

Here, Appellant fails to specifically name any witnesses that counsel

should have called, meaningfully explain what testimony they would have

offered, or discuss how/why their testimony would have impacted the trial

court’s sentencing decision. His cursory assertion that these unnamed

witnesses would have offered “beneficial testimony” is insufficient to

demonstrate that he was prejudiced by their absence from the sentencing

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proceeding. This is especially true where, as the PCRA court stresses, it “had

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Commonwealth v. Johnson
966 A.2d 523 (Supreme Court of Pennsylvania, 2009)
Commonwealth v. Morales
701 A.2d 516 (Supreme Court of Pennsylvania, 1997)
Commonwealth v. Travaglia
661 A.2d 352 (Supreme Court of Pennsylvania, 1995)
Commonwealth v. Sneed
45 A.3d 1096 (Supreme Court of Pennsylvania, 2012)
Commonwealth v. Matias
63 A.3d 807 (Superior Court of Pennsylvania, 2013)

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Bluebook (online)
Com. v. Ritchie, C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-ritchie-c-pasuperct-2025.