### Drug Dealer’s Bid for Post-Prison Relief Shot Down
Pennsylvania’s Superior Court swiftly rejected Rakim Lamar Johnson’s second attempt at post-conviction relief, ruling he’s ineligible because he’s no longer serving time for his drug crimes. The court affirmed a lower court’s dismissal of his PCRA petition as meritless, emphasizing that PCRA relief demands a petitioner still be under sentence—imprisonment, probation, or parole. Johnson, now free, walked away empty-handed.
It all started in October 2016 when Johnson, needing a ride from Pittsburgh to Altoona, handed an undercover cop heroin and crack cocaine instead of cash. Busted for possession with intent to deliver (PWID) and criminal use of a communication facility (CUCF), he cut a deal: a negotiated guilty plea. On September 1, 2017, the Blair County judge slapped him with 18 months to 5 years for PWID, a concurrent 6 to 24 months for CUCF, and credit for time served. No direct appeal followed.
Johnson’s first PCRA shot in March 2021 flopped as untimely; Superior Court upheld that in 2022, and the state Supreme Court denied review in 2023. Undeterred, he filed a second pro se petition in April 2024, crying ineffective counsel and after-discovered evidence. The PCRA court dismissed it as meritless on March 12, 2025, sparking this appeal.
The core legal fight? PCRA eligibility under 42 Pa.C.S. § 9543(a)(1)(i), which flat-out requires petitioners to be “currently serving a sentence” for the challenged conviction. Courts have long held—even if you file while incarcerated, relief vanishes once your sentence ends, per precedents like *Commonwealth v. Williams*. Johnson’s max-out date? No later than September 1, 2022, with credit. By then, he was done—free and thus ineligible.
Reviewing for legal error and record support, the Superior Court panel—Judges Olson, Dubow, and Bender—had no choice. Johnson’s claims of counsel failings and new evidence? Irrelevant without eligibility. Order affirmed December 8, 2025. Case closed.