Pennsylvania DUI Lawyers Blog
In Pennsylvania, driving with a license suspended due to a DUI conviction carries serious consequences, including mandatory sentencing provisions and enhanced penalties for repeat offenses. When a defendant enters a guilty plea to such a charge, the law provides a structured framework for evaluating whether the plea was made knowingly and voluntarily. As such, later attempts to revoke that plea or seek a different sentence can be challenging. A recent Pennsylvania DUI case illustrates these principles, emphasizing that post-sentence efforts to withdraw a guilty plea must demonstrate a manifest injustice and that negotiated plea agreements generally foreclose discretionary sentencing challenges. If you are facing charges for driving with a suspended license or seeking to contest a prior plea, it is essential to understand the legal standards involved and work with a qualified Pennsylvania DUI defense attorney.
Factual and Procedural History
It is reported that the defendant was arrested for driving while his license was suspended due to a prior DUI conviction. The Commonwealth noted that this was not the defendant’s first such incident, as he had previously been cited twice before for driving with a suspended license under similar circumstances.
It is further reported that the defendant entered into a negotiated guilty plea on July 1, 2024, to one count of driving with a DUI-suspended license in violation of 75 Pa.C.S.A. § 1543(b). As part of the agreement, the court imposed a sentence of 12 months of restrictive probation, with the first six months to be served on house arrest. The record indicates that the defendant completed both a written guilty plea colloquy and an oral colloquy in court, during which he affirmed his understanding of the charges, potential penalties, and the rights he was waiving by pleading guilty.
It is alleged that shortly after sentencing, the defendant filed a post-sentence motion seeking to withdraw his plea or obtain a modification of his sentence. He argued that he had not intended to plead guilty that day, believing he only appeared in court to address an outstanding bench warrant. He further claimed he was rushed into the plea and hoped instead for a sentence of time served, which would allow him to relocate to Florida without the restrictions of house arrest.
It is reported that the trial court denied the post-sentence motion, finding that the defendant’s plea was knowing, voluntary, and intelligent. The defendant then filed a timely appeal, challenging both the denial of his motion to withdraw the plea and the imposition of the agreed-upon sentence.
Evaluation of Guilty Pleas in Pennsylvania DUI Cases
It is further reported that the reviewing court applied the “manifest injustice” standard to the defendant’s attempt to withdraw his guilty plea after sentencing. Under Pennsylvania law, post-sentence motions to withdraw a guilty plea are disfavored and subject to heightened scrutiny. The courts aim to prevent defendants from using guilty pleas as a trial run, only to withdraw them when the outcome is unsatisfactory. To succeed, the defendant must show that the plea was not entered knowingly, voluntarily, or intelligently, or that a manifest injustice would result if withdrawal were denied.
The court emphasized that both the written and oral plea colloquies reflected the defendant’s understanding of the plea and its consequences. During the in-court hearing, the defendant confirmed under oath that he had reviewed the colloquy with counsel, understood the maximum sentence, and wished to plead guilty. The Commonwealth summarized the factual basis for the plea, which the defendant admitted was accurate. The court found that the record was clear and comprehensive and that the defendant was bound by the statements he made under oath during the proceedings.
According to precedent, a defendant cannot later contradict his own in-court affirmations to assert that the plea was involuntary. The court noted that the law does not require a defendant to be pleased with the outcome; it only requires that the decision to plead guilty be the result of an informed and voluntary choice. As such, the reviewing court found no error in the trial court’s denial of the post-sentence motion.
Meet with a Skilled Pennsylvania DUI Defense Attorney Today
If you were charged with driving while your license was suspended for a prior DUI, or if you believe your guilty plea was entered under pressure or misunderstanding, it is important to seek legal guidance immediately. Attorney Zachary B. Cooper is a knowledgeable and experienced Pennsylvania DUI defense attorney who understands how to challenge improperly obtained pleas and protect your rights at sentencing. To schedule a confidential consultation, contact Mr. Cooper at (215) 542-0800 or reach out through the online form.