### Drug Dealer’s PCRA Bid Shot Down: No Sentence, No Relief
Pennsylvania’s Superior Court slammed the door on Rakim Lamar Johnson’s second bid for post-conviction relief, ruling he’s ineligible because he’s no longer serving time for his drug crimes. The court affirmed the denial of his PCRA petition as meritless, emphasizing that PCRA eligibility vanishes once a sentence ends—regardless of fresh claims like ineffective counsel or new evidence.
It all started in October 2016 when Johnson, needing a lift from Pittsburgh to Altoona, handed an undercover cop heroin and crack cocaine instead of cash. He copped a negotiated guilty plea to possession with intent to deliver (PWID) and criminal use of a communication facility (CUCF). On September 1, 2017, the Blair County judge hit him with 18 months to 5 years on the PWID count, a concurrent 6-to-24 months on CUCF, and credit for time served. Johnson skipped a direct appeal, letting the clock tick.
Fast-forward to March 2021: Johnson’s first PCRA shot at undoing his plea got tossed as untimely, a decision the Superior Court upheld in 2022 and the state Supreme Court declined to review. Undeterred, he filed a second pro se petition in April 2024, crying ineffective assistance and after-discovered evidence. By March 12, 2025, the PCRA court dismissed it outright.
The legal hook? Pennsylvania’s PCRA demands petitioners be “currently serving a sentence of imprisonment, probation or parole” for the challenged conviction (42 Pa.C.S. § 9543(a)(1)(i)). Johnson’s max-out date was no later than September 1, 2022—two years before his second filing. Citing precedent like *Commonwealth v. Williams*, the Superior Court made it crystal clear: Finish your sentence, and you’re out of luck, even if you file mid-stream. No eligibility, no dice—order affirmed December 8, 2025.