In Commonwealth v. Cox, the PA Supreme Court considered an appeal from the denial of PCRA relief in a capital case. The defendant claimed he was intellectually disabled and could not be executed. The Court focused on whether the defendant had “significant adaptive limitations.” The Court found the PCRA court’s weighing of that factor deficient … Read more
The PA Supreme Court in Commonwealth v. Small overruled its prior precedent and tossed the “public record presumption.” Traditionally, a defendant, who filed a PCRA petition, could circumvent the statutory one-year filing deadline by proving they had uncovered a newly-discovered fact. But if that newly-discovered fact was a matter of public record, then a presumption existed … Read more
In Commonwealth v. Smith, the PA Superior Court held that the defendant’s petition to remove himself from sex offender registration was not an untimely PCRA petition. Relying on Commonwealth v. Lacombe, the Court held that the lower court was obligated to review the merits of the claim.
In Commonwealth v. McLaughlin, the PA Superior Court affirmed the dismissal of the defendant’s writ of coram nobis. The Court held: 1. the defendant’s claim of judicial bias was cognizable under the PCRA and cannot serve as the basis for coram nobis relief; 2. the defendant could not obtain PCRA relief on his judicial bias … Read more
In Commonwealth v. Williams, the Superior Court held that, where counsel has effectively discontinued working on a defendant’s behalf, a pro se filing does not offend considerations of hybrid representation. In the instant case, the trial court should have considered post-sentence letters directly from the defendant as timely post-sentence motions.
In Commonwealth v. Epps, the Superior Court revisited a newsworthy Philadelphia murderer who has collaterally attacked his convictions. Here, the Superior Court denied relief, finding the myriad claims of ineffective assistance of trial counsel lacked merit.
In Commonwealth v. Betts, the Superior Court set forth the proper procedure for criminal defendants who wish to allege that their attorneys rendered ineffective assistance of counsel during PCRA proceedings in the Courts of Common Pleas. Defendants are obliged to raise their claims in response to the lower courts’ notice of intent to dismiss pursuant … Read more
In Commonwealth v. Little, the Superior Court held that the defendant’s trial counsel was ineffective for not objecting to the judge’s ruling on an evidentiary issue and, thus, failing to preserve the issue for direct appellate review. Under a strict interpretation of the case law concerning the prejudice prong for a claim of ineffective assistance, counsel’s … Read more
In 1994, the defendant entered a guilty plea to kidnapping a minor and has long since served his sentence. In 2019, he filed a coram nobis petition challenging his sex offender registration. In Commonwealth v. Duncan, the Court ruled that the petition for coram nobis could proceed and it need not be treated as an untimely … Read more
Commonwealth v. Reid is one of several similar cases that have passed through the Supreme Court involving former Chief Justice Castille’s role as the elected DA of Philadelphia. In Reid’s case, the Court determined that the PCRA court did not have jurisdiction to reinstate Reid’s nunc pro tunc right to appeal. The Court found that … Read more