In Commonwealth v. Knight, the Pennsylvania Supreme Court reviewed the defendant’s death sentence. The Court ruled that most of the defendant’s claims were waived. In addressing his claim that PA’s death penalty statute is unconstitutional, the Court chided the defendant for incorporating by reference in his brief a different brief authored by another attorney. The Court explained that incorporation by reference is an unacceptable manner of appellate advocacy for the proper presentation of a claim for relief. The Court then affirmed the trial court’s refusal to give an Atkins instruction (Pa. SSJI (Crim), § 15.2502F.2) because the defendant failed to offer any evidence of an IQ score, documented prior to age 18, within the range established by Commonwealth v. Miller, 888 A.2d 624 (Pa. 2005), and Commonwealth v. Sanchez, 36 A.3d 24 (Pa. 2001).