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Commonwealth v. Friedland

Pennsylvania Superior Court

December 11, 2020

Friedland filed a PCRA petition and specifically requested that counsel not be appointed to represent him in his PCRA proceedings. After a Grazier hearing, the PCRA court granted Friedland’s request to proceed pro se. Later, the court reviewed the filings and sent out a 907 Notice of dismissal. Only then did Friedland ask for a lawyer. The PCRA court denied the request and dismissed the petition. On appeal, Friedland argued that the PCRA court erred in refusing his request for counsel on a first PCRA petition prior to dismissal of his pro se PCRA where he indicated prior to dismissal that he needed the “help of an attorney” and could not, “fulfill his burden” while acting pro se. In Commonwealth v. Friedland, the Pennsylvania Superior Court affirmed the dismissal of the petition, holding that to require the appointment of counsel after the PCRA court had conducted a comprehensive Grazier hearing and later found no merit to the PCRA petition’s issues, would inappropriately provide the defendant a second attempt at post-conviction relief.

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