Commonwealth v. Vo

The PCRA petitioner was represented by counsel during the PCRA proceedings in Common Pleas, but a new attorney entered before the Superior Court on appeal from the denial of that PCRA petition. The new counsel raised issues of ineffective assistance of prior PCRA counsel. The Superior Court detailed an often-conflicting body of law before holding that the petitioner could not raise the issues on appeal. But the Superior Court then remanded to the PCRA court for further proceedings, as not notice under Rule 907 was issued.