Commonwealth v. Crumbley

The Pennsylvania Superior Court dealt with what will surely become a common issue in light of Commonwealth v. Bradley: claims of ineffective assistance of counsel raised for the first time on appeal. Here, the Superior Court affirmed the denial of post-conviction relief. The case’s procedural posture is more noteworthy than the substance of any particular claim. The appellant filed a PCRA petition challenging his murder conviction. The trial court denied relief, as did the Superior Court. While the appellant’s allocatur petition was pending, the Pennsylvania Supreme Court issued Bradley. The high court then remanded the appellant’s matter to the Superior Court to consider allegations of ineffective assistance of PCRA counsel. Upon remand, the Superior Court held that the appellant failed to prove each element of the Pierce test for ineffective assistance of counsel.

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