Parole Violation Puts Convicted Insurance Fraudster Back in Jail
Post 4991
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Facts
In Commonwealth Of Pennsylvania v. Kalani Watts, Nos. 2399 EDA 2023, 895 EDA 2024, No. J-S37026-24, Superior Court of Pennsylvania (January 27, 2025) Watts entered a negotiated guilty plea to one count each of obtaining possession of a controlled substance by misrepresentation, fraud, forgery or subterfuge, and insurance fraud. On July 21, 2014, in accordance with the plea agreement, the trial court imposed an aggregate sentence of 6 to 12 years in prison.
Watts also pled guilty to one count of receiving stolen property. On September 3, 2014, the trial court sentenced Appellant to 16 to 36 months in prison, to run concurrently with Appellant’s sentence in the drug and insurance fraud case.
Watts alleged he was paroled on 6-20-19, and moved thereafter to the State of Georgia. Three years later, Watts was arrested on misdemeanors and returned back to Pennsylvania on a parole violation. Upon being seen by the Pennsylvania Board of Probation and Parole (Parole Board), Watts was informed that his maximum sentence was moved from 7-12-2026 to 4-29-29.
The Appeal
In this consolidated appeal, Kalani Watts (Appellant) appeals, pro se, from the orders dismissing as untimely his first petitions filed under the Post Conviction Relief Act (PCRA), 42 Pa.C.S.A. §§ 9541-9546.
Post Conviction Relief
Appellant filed identical, pro se PCRA petitions at two dockets. Appellant filled out portions of a pre-printed PCRA petition form and also incorporated an attached “Petition for Enforcement of Negotiated Plea Agreement” (Attachment).
The PCRA court further observed that Appellant’s petitions appeared to challenge the Parole Board’s decision to revoke his parole and pull his street time. In the alternative, the PCRA court determined that the Parole Board’s decision did not constitute a violation of Appellant’s plea agreement.
Analysis
Pro se litigants must comply with the procedural rules set forth in the Pennsylvania Rules of Court.
Preliminarily, although the Court was willing to construe liberally materials filed by a pro se litigant, a pro se appellant enjoys no special benefit. To the contrary, any person choosing to represent himself in a legal proceeding must, to a reasonable extent, assume that his lack of expertise and legal training will be his undoing.
Here, though Appellant cites various provisions of the federal and state constitutions, he fails to identify any decision of the United States Supreme Court or Pennsylvania Supreme Court recognizing a new constitutional right.
As Appellant has waived each of his issues raised on appeal, the Court of Appeals affirmed the PCRA court’s orders dismissing his petitions.
ZALMA OPINION
People who engage in criminal conduct, especially when that conduct is insurance fraud, are not members of MENSA. Mr. Watts was a regular, albeit inept, criminal. He was lucky enough to be paroled only to be put back in jail for breaching the conditions of his parole by committing some misdemeanors. He then tried to change his sentence by applying as his own attorney for post conviction relief. That also failed because the bases he claimed were not established.
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