Commonwealth of Pennsylvania, Appellee v. Terrance Washington, Appellant

Summary

The Supreme Court of Pennsylvania held that the new constitutional rule announced in Alleyne v. United States — that any fact increasing a mandatory minimum penalty must be found by a jury beyond a reasonable doubt — does not apply retroactively to cases on collateral review. Because Appellant's sentences became final in 2006, seven years before Alleyne was decided in 2013, and because the Alleyne rule is procedural rather than substantive and not a 'watershed' rule of criminal procedure under Teague v. Lane, his mandatory minimum sentences are not illegal on account of Alleyne. The Court also declined to adopt an independent state-level retroactivity jurisprudence that would lower Teague's threshold, holding that Teague remains Pennsylvania's default approach to retrospective application of new federal constitutional procedural rules. Justice Todd filed a concurrence joined by Justice Donohue objecting that footnote 10 relaxes courts' obligation to address threshold jurisprudential matters; Justice Dougherty filed a concurrence emphasizing the limiting principle for 'illegal sentence' claims and the PCRA's constraints.