For its part, the Commonwealth recognizes the critical role that plea bargains play in our system of criminal justice and the necessity of enforcing their terms "to prevent any perversion of the system." Commonwealth's Brief at 7 (citing Commonwealth v. Snook, 230 A.3d 438, 444 (Pa. Super. 2020)). It contends, however, that Schell's registration as a Tier I offender was not a term included in the plea agreement but was simply an error by the Commonwealth
Ordinarily, "a PCRA petitioner is entitled to the assistance of counsel to litigate a first PCRA petition." Commonwealth v. Snook, 230 A.3d 438, 446 n.2 (Pa. Super. 2020);
The enforcement of a plea agreement is governed by the principles of contract law. Commonwealth v. Snook, 230 A.3d 438, 444 (Pa.Super. 2020). A defendant is only entitled to relief if the allegedly breached term was made part of the plea agreement.
We are cognizant that Appellant was not appointed counsel when litigating his first PCRA petition or the instant petition. Ordinarily, "a PCRA petitioner is entitled to the assistance of counsel to litigate a first PCRA petition." Commonwealth v. Snook, 230 A.3d 438, 446 n.2 (Pa.Super. 2020).
If the court determines that an alleged term was reasonably understood by the parties to be part of the agreement, "then the convicted criminal is entitled to specific performance of the term." Commonwealth v. Snook, 230 A.3d 438, 444-45 (Pa.Super. 2020) (cleaned up).
"A petition for collateral relief will generally be considered a PCRA petition if it raises issues cognizable under the PCRA." Commonwealth v. Snook, 230 A.3d 438, 443 (Pa. Super. 2020) (citations omitted).
In reviewing the terms of a plea agreement, we approach the plea agreement as a contract, "to be analyzed under contract-law standards." Commonwealth v. Snook, 230 A.3d 438, 444 (Pa. Super. 2020). In a dispute over the terms of a plea agreement, "[a]ny ambiguities … will be construed against the Government." Id.
In reviewing the terms of a plea agreement, we approach the plea agreement as a contract, "to be analyzed under contract-law standards." Commonwealth v. Snook, 230 A.3d 438, 444 (Pa. Super. 2020). In a dispute over the terms of a plea agreement, "[a]ny ambiguities . . . will be construed against the Government." Id. Here, the Commonwealth contends that Appellant waived his Rule 600 issue by entering a guilty plea.
This Court has long recognized the critical role that plea agreements play in our criminal justice system. See Commonwealth v. Snook, 230 A.3d 438, 444 (Pa. Super. 2020) (noting that ninety-four percent of state convictions are the result of plea agreements). When a defendant enters a plea agreement, he or she waives his or her right to proof beyond a reasonable doubt.
Commonwealth v. Snook, 230 A.3d 438, 444 (Pa. Super. 2020) (citation, brackets, and some ellipses omitted).