Com. v. Sledge, L.

Superior Court of Pennsylvania·Decided August 18, 2026·No. 138 WDA 2026·Unpublished·Stevens

Opinion

J-S19040-26

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

:

v. :

:

:

LARRY ALLEN SLEDGE :

:

Appellant : No. 138 WDA 2026

Appeal from the PCRA Order Entered December 22, 2025 In the Court of Common Pleas of Erie County Criminal Division at No(s):

CP-25-CR-0000722-2020

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA

:

v. :

:

:

LARRY ALLEN SLEDGE :

:

Appellant : No. 139 WDA 2026

Appeal from the PCRA Order Entered December 22, 2025 In the Court of Common Pleas of Erie County Criminal Division at No(s):

CP-25-CR-0000388-2020

BEFORE: SULLIVAN, J., NEUMAN, J., and STEVENS, P.J.E.* MEMORANDUM BY STEVENS, P.J.E.: FILED: AUGUST 18, 2026 In these consolidated appeals,1 Larry Allen Sledge appeals from the December 22, 2025 order dismissing his petition filed pursuant to the Post

* Former Justice specially assigned to the Superior Court.

1 Appellant’s appeals at Nos. 138 WDA 2025 and 139 WDA 2025 were consolidated by per curiam order of this Court on February 17, 2026.

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Conviction Relief Act (“PCRA”), 42 Pa.C.S.A. §§ 9541-9546. After careful review, we affirm.

This case stems from an incident that occurred on January 14, 2020, wherein Appellant repeatedly threatened to kill Jessica Crouch (“Victim”), pistol-whipped her in the face, and ultimately shot her twice in her head, leaving her partially blind in one eye. A prior panel of this Court summarized the relevant procedural history of this case as follows:

On January 14, 2020, Appellant shot [Victim] in the head. When police responded, Victim identified Appellant as the shooter.

In January 2020, the Commonwealth filed a criminal complaint against Appellant at Docket Number 388 of 2020 (“Docket 388”), charging him with attempted homicide and related crimes.

In February 2020, Victim reported receiving a letter from the Erie County Prison asking her to drop the charges against Appellant. While the letter contained the signature of an inmate other than Appellant and a third inmate’s identification number, Victim identified the handwriting as Appellant’s handwriting.

Accordingly, in March 2020, the Commonwealth charged Appellant at Docket Number 722 of 2020 (“Docket 722”) with intimidation of a witness.

On December 28, 2021, following delays related to the COVID-19 pandemic and several continuances, the trial court granted Appellant’s request to proceed pro se with standby counsel.

On June 6, 2022, Appellant filed pro se a “Habeas Corpus Motion to Dismiss Pursuant to Pa.R.Crim.P.

600[.]” On June 9, 2022, the trial court stamped the motion “denied,” without scheduling a hearing or providing analysis.

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On July 11, 2022, Appellant filed a “Motion for Case Dismissal/Nominal Bond Pursuant to Rule 600[.]” The trial court, again, denied the motion without a hearing or analysis on August 8, 2022, the first day of Appellant’s trial.

On August 12, 2022, the jury convicted Appellant of Attempted Homicide and related charges, at Docket 388, and Intimidation of a Witness, at Docket 722.

On October 31, 2022, following the appointment of counsel, the trial court sentenced Appellant to an aggregate term of 20 to 40 years of incarceration at Docket 388 and a consecutive term of 6 to 12 years of incarceration at Docket 722

On March 5, 2024, following reinstatement of his appellate rights nunc pro tunc, this Court affirmed the judgments of sentence. Commonwealth v.

Sledge, 2024 WL 940118 (Pa.Super. filed March 5, 2024) (unpublished decision). Notably, this Court rejected Appellant’s Rule 600 claim, concluding that Appellant’s counseled brief “failed to preserve his Rule 600 challenge for appellate review” based upon lack of compliance with Pa.R.A.P. 2117(c) and 2119(e), which required him to cite to the location in the record where he preserved the issue before the trial court.

Id. at *3.

On April 16, 2024. Appellant filed [a] pro se [] PCRA petition, and appointed PCRA counsel filed a supplement on June 28, 2024, presenting several issues including a claim of ineffective assistance of direct appeal counsel for failure to preserve Appellant’s Rule 600 claim.

On August 20, 2024, the PCRA court issued a Rule 907 Notice of Intent to Dismiss Without a Hearing. The court dismissed the petition on September 24, 2024.

Commonwealth v. Sledge, 348 A.3d 717 (Pa.Super. 2025) (unpublished memorandum at *1-2) (footnote and some citations omitted).

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On September 12, 2025, a panel this Court vacated the PCRA court’s September 24, 2024 order dismissing his PCRA Petition, and remanded this matter for the PCRA court to hold an evidentiary hearing on Appellant’s Rule 600 claims. See id. The PCRA conducted hearings on October 28 and November 21, 2025. Thereafter, on December 22, 2025, the PCRA court issued an opinion and order finding that Appellant’s Rule 600 claim meritless and dismissing his PCRA petition. This timely appeal followed.2 Appellant raises the following issues for our review:

A. Whether the trial and ensuing convictions are rendered void in that there was a rule 600 violation that was not duly litigated and adjudicated in that prior court review of this claim has proceeded under the misapprehension and miscalculation of the accurate time period and further compounded by the [PCRA] court’s treatment and adjudication of this claim on remand?

B. Whether the [PCRA] court abused its discretion in permitting [Appellant] to proceed pro se wherein any cursory evaluation of his mental competency to act in that capacity would have disclosed a lengthy and significant mental health history precluding that measure, which prejudice was further exacberbated (sic) by appointing stand-by counsel who possessed competency impediments as well given a patent conflict of interest thereby combining to deprive [Appellant] of his fundamental right to counsel or a legal predicate for a cognizable waiver of that right?

2 Appellant and the PCRA court have complied with Pa.R.A.P. 1925.

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C. Whether [Appellant] was afforded ineffective assistance of counsel for failure to pursue and preserve a suppression claim predicated on a material gap in the chain of custody pertaining to critical physical evidence in the custody of the police subsequent t[o] arrest thereby compromising the ability of the Commonwealth to lay a proper foundation for the admission of the evidence relating to forensic testing[]?

D. Whether the [PCRA] court abused its discretion and committed legal error and failing to accept and consider the police misconduct alleged as per [Appellant’s] proffering of a claim of afterdiscovered evidence in the nature of a witness affidavit presented to the [PCRA] court reciting the affiant’s knowledge of a statement by the police implicating them in the fabrication of evidence and further corroborating the former claim rendering suspect the proper chain of custody of the physical evidence?

E. Whether [Appellant] was afforded ineffective assistance of counsel in that defense counsel failed to assert and preserve a claim of prosecutorial misconduct relating to the Commonwealth’s making personal commentary and conclusions as to the guilty (sic) of [Appellant] during closing argument and in purposely or recklessly (sic) making false statements or mischaracterization of the results of forensic testing offered into evidence?

F. Whether [Appellant] was afforded ineffective assistance of counsel in that defense counsel failed to present and preserve a challenge to the testimony relating to a purported positive GSR test result in the Commonmwealth’s (sic) casein -chief wherein there was no proof or proper foundation laid as to any such test ever being performed?

G. Whether [Appellant] was afforded ineffective assistance of counsel in that appellate counsel

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