246 Pennsylvania opinions name it 2 courts 2010–2026 79 in the last five years
The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Commonwealth v. Graziergreen2 sentences2026On January 20, 2022, Attorney Fryling filed an “Application to remand for a Grazier[1] Hearing and/or to Appoint Substitute Counsel.” On February 1, 2022, this Court issued a per curiam order remanding for the PCRA court to hold a Grazier hearing and “determine whether Appellant wishes to proceed pro se and if Appellant’s decision to proceed pro se is knowing, voluntary, and intelligent.” Order, 2/1/22, at 1 (single page). [1] Commonwealth v. Grazier, 713 A.2d 81 (Pa. 1998). 2026On January 20, 2022, Attorney Fryling filed an “Application to remand for a Grazier[1] Hearing and/or to Appoint Substitute Counsel.” On February 1, 2022, this Court issued a per curiam order remanding for the PCRA court to hold a Grazier hearing and “determine whether Appellant wishes to proceed pro se and if Appellant’s decision to proceed pro se is knowing, voluntary, and intelligent.” Order, 2/1/22, at 1 (single page). [1] Commonwealth v. Grazier, 713 A.2d 81 (Pa. 1998). | 49 | 150 |
Commonwealth v. Robinsongreen2 sentences2023Id. at 460 ; see also Stossel, 17 A.3d at 1290 (holding -4- J-S39045-22 that the defendant checking a box on pre-printed PCRA petition form indicating that he did not want the PCRA court to appoint counsel for him was not sufficient “to waive [his] right to representation”, vacating the order denying the defendant’s first PCRA petition as untimely, and remanding for a Grazier hearing). 2023Id. at 460 ; see also Stossel, 17 A.3d at 1290 (holding -4- J-S39045-22 that the defendant checking a box on pre-printed PCRA petition form indicating that he did not want the PCRA court to appoint counsel for him was not sufficient “to waive [his] right to representation”, vacating the order denying the defendant’s first PCRA petition as untimely, and remanding for a Grazier hearing). | 25 | 32 |
Commonwealth v. Stosselgreen2 sentences2026See generally Commonwealth v. Stossel, 17 A.3d 1286, 1288-1290 (Pa. Super. 2011) (discussing purpose and importance of Grazier hearing). 2024Commonwealth v. Stossel, 17 A.3d 1286 , 1289 (Pa. Super. 2011). -6- J-S08044-24 The record belies Appellant’s contention, as it shows that the PCRA court had ample opportunity prior to the Grazier hearing to witness Appellant’s articulate and capable pro se presentation of his case through testimony and argument at the 2021 PCRA evidentiary hearing. | 23 | 26 |
Commonwealth v. Wilsongreen2 sentences2016See, e.g., Commonwealth v. Wilson, 67 A.3d 736, 738 (Pa. 2013) (explaining that “[Wilson] filed a pro se notice of appeal; it is not clear why his court-appointed counsel did not file the notice,” and proceeding to review the merits of Wilson’s case without further discussion); Commonwealth v. Robinson, 970 A.2d 455, 457 (Pa. Super. 2009) (remanding for a Grazier hearing where, after the denial of Robinson’s counseled petition pursuant to the Post Conviction Relief Act, Robinson filed a timely pro se appeal and a petition requesting that he be allowed to proceed pro se, and the PCRA court ente 2016See, e.g., Commonwealth v. Wilson, 67 A.3d 736, 738 (Pa. 2013) (explaining that “[Wilson] filed a pro se notice of appeal; it is not clear why his court-appointed counsel did not file the notice,” and proceeding to review the merits of Wilson’s case without further discussion); Commonwealth v. Robinson, 970 A.2d 455, 457 (Pa. Super. 2009) (remanding for a Grazier hearing where, after the denial of Robinson’s counseled petition pursuant to the Post Conviction Relief Act, Robinson filed a timely pro se appeal and a petition requesting that he be allowed to proceed pro se, and the PCRA court ente | 5 | 5 |
Commonwealth v. Figueroagreen2 sentences2018We note that a Grazier hearing was appropriate under Commonwealth v. Figueroa , 29 A.3d 1177 (Pa. Super. 2011) (holding that an on-the-record colloquy is necessary to ensure that a defendant/PCRA Petitioner understands his right to counsel and to confirm his right and desire to proceed pro se ). 2018We note that a Grazier hearing was appropriate under Commonwealth v. Figueroa , 29 A.3d 1177 (Pa. Super. 2011) (holding that an on-the-record colloquy is necessary to ensure that a defendant/PCRA Petitioner understands his right to counsel and to confirm his right and desire to proceed pro se ). | 3 | 5 |
Commonwealth v. Jettegreen2 sentences2020See Commonwealth v. Jette, 23 A.3d 1032, 1044 (Pa. 2011) (proper response to any pro se pleading is to refer pleading to counsel, and to take no further action on pro se pleading unless counsel forwards a motion). -4- J-S12026-20 15th, directing the trial court to conduct a Grazier hearing and determine whether Appellant’s waiver of counsel was knowing, intelligent, and voluntary. 2020See Commonwealth v. Jette, 23 A.3d 1032, 1044 (Pa. 2011) (proper response to any pro se pleading is to refer pleading to counsel, and to take no further action on pro se pleading unless counsel forwards a motion). -4- J-S12026-20 15th, directing the trial court to conduct a Grazier hearing and determine whether Appellant’s waiver of counsel was knowing, intelligent, and voluntary. | 3 | 4 |
Commonwealth v. Williamsgreen2 sentences2022See id. 4 Although the PCRA court quotes from the transcript of the December 2, 2021 Grazier hearing in its Rule 1925(a) opinion, see PCRA Ct. Op. at 6-8, that transcript is not included in certified record. 2020See Commonwealth v. Williams, 151 A.3d 621, 623 (Pa. Super. 2016) (explaining that hybrid representation is not permitted). 7 Attorney McHale was suspended from the practice of law for a period of one year and one day, by consent, on September 20, 2019, after Mays had filed a pro se Notice of Appeal in this case. | 2 | 3 |
Commonwealth v. Williamsgreen2 sentences2020This is particularly perplexing in light of the knowledge that Appellant originally - 16 - J-S28010-20 see also, e.g., Commonwealth v. Williams, 167 A.3d 1, 6 (Pa.Super. 2017) (“[T]he best resolution of this case is to vacate and remand for [substitute] PCRA appellate counsel to file a new amended PCRA petition on Appellant’s behalf and for further proceedings.”); Commonwealth v. Willis, 29 A.3d 393, 400 (Pa.Super. 2011) (remanding for appointment of new PCRA counsel where both the PCRA court and prior PCRA counsel were “responsible” for the effective denial of a PCRA petitioner’s right to cou 2020This is particularly perplexing in light of the knowledge that Appellant originally - 16 - J-S28010-20 see also, e.g., Commonwealth v. Williams, 167 A.3d 1, 6 (Pa.Super. 2017) (“[T]he best resolution of this case is to vacate and remand for [substitute] PCRA appellate counsel to file a new amended PCRA petition on Appellant’s behalf and for further proceedings.”); Commonwealth v. Willis, 29 A.3d 393, 400 (Pa.Super. 2011) (remanding for appointment of new PCRA counsel where both the PCRA court and prior PCRA counsel were “responsible” for the effective denial of a PCRA petitioner’s right to cou | 2 | 2 |
Commonwealth v. Ousleygreen2 sentences2016See Commonwealth v. Ousley, 21 A.3d 1238, 1242 (Pa. Super. 2011) 2 We note that Black requests a Grazier hearing. 2016See Commonwealth v. Ousley, 21 A.3d 1238, 1242 (Pa. Super. 2011) 2 We note that Black requests a Grazier hearing. | 2 | 2 |
Commonwealth v. Willisgreen2 sentences2020This is particularly perplexing in light of the knowledge that Appellant originally - 16 - J-S28010-20 see also, e.g., Commonwealth v. Williams, 167 A.3d 1, 6 (Pa.Super. 2017) (“[T]he best resolution of this case is to vacate and remand for [substitute] PCRA appellate counsel to file a new amended PCRA petition on Appellant’s behalf and for further proceedings.”); Commonwealth v. Willis, 29 A.3d 393, 400 (Pa.Super. 2011) (remanding for appointment of new PCRA counsel where both the PCRA court and prior PCRA counsel were “responsible” for the effective denial of a PCRA petitioner’s right to cou 2020This is particularly perplexing in light of the knowledge that Appellant originally - 16 - J-S28010-20 see also, e.g., Commonwealth v. Williams, 167 A.3d 1, 6 (Pa.Super. 2017) (“[T]he best resolution of this case is to vacate and remand for [substitute] PCRA appellate counsel to file a new amended PCRA petition on Appellant’s behalf and for further proceedings.”); Commonwealth v. Willis, 29 A.3d 393, 400 (Pa.Super. 2011) (remanding for appointment of new PCRA counsel where both the PCRA court and prior PCRA counsel were “responsible” for the effective denial of a PCRA petitioner’s right to cou | 2 | 2 |
Commonwealth v. Henkelgreen2 sentences2015See Henkel, supra; Ford, supra. Additionally, PCRA counsel stated at the Grazier hearing that he was actively working on Melo’s appellate brief. -5- J-S73041-14 address it. 2015See Henkel, supra; Ford, supra. Additionally, PCRA counsel stated at the Grazier hearing that he was actively working on Melo’s appellate brief. -5- J-S73041-14 address it. | 2 | 2 |
Commonwealth v. Turnergreen2 sentences2020Appellant’s Brief at 5.4 When reviewing the propriety of an order denying PCRA relief, we consider the record “in the light most favorable to the prevailing party at the PCRA level.” Commonwealth v. Stultz, 114 A.3d 865 , 872 (Pa. Super. ____________________________________________ 4 Due to the procedural posture of this case, i.e., the PCRA court granted counsel’s motion to withdraw and permitted Appellant to proceed pro se after a Grazier hearing, we need not conduct a traditional Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988), and Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (en 2020Appellant’s Brief at 5.4 When reviewing the propriety of an order denying PCRA relief, we consider the record “in the light most favorable to the prevailing party at the PCRA level.” Commonwealth v. Stultz, 114 A.3d 865 , 872 (Pa. Super. ____________________________________________ 4 Due to the procedural posture of this case, i.e., the PCRA court granted counsel’s motion to withdraw and permitted Appellant to proceed pro se after a Grazier hearing, we need not conduct a traditional Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988), and Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (en | 1 | 8 |
Com. v. Betts, T.green2 sentences2024On June 24, 2022, the trial court held a Grazier hearing.2 During the hearing, the PCRA court advised Warren of his right to have new counsel appointed to represent him, given his claims of PCRA counsel’s ineffectiveness, pursuant to Commonwealth v. Betts, 240 A.3d 616 (Pa. Super. 2020). 2024On June 24, 2022, the trial court held a Grazier hearing.2 During the hearing, the PCRA court advised Warren of his right to have new counsel appointed to represent him, given his claims of PCRA counsel’s ineffectiveness, pursuant to Commonwealth v. Betts, 240 A.3d 616 (Pa. Super. 2020). | 1 | 3 |
Commonwealth v. Ellisgreen2 sentences2020On April Commonwealth v. Grazier, 552 Pa. 9 , 713 A.2d 81 (1998). 2 Commonwealth v. Ellis, 534 Pa. 176 , 626 A.2d 1137 (1993); Commonwealth v. Jette, 611 Pa. 166 , 23 A.3d 1032 (2011). 2 29th, the trial court conducted the remanded Grazier hearing and ruled that the defendant's request to proceed pro se was knowing, intelligent and voluntary and as such Appellant was permitted to self-represent with his court -appointed attorney to remain as back-up counsel. 2020On April Commonwealth v. Grazier, 552 Pa. 9 , 713 A.2d 81 (1998). 2 Commonwealth v. Ellis, 534 Pa. 176 , 626 A.2d 1137 (1993); Commonwealth v. Jette, 611 Pa. 166 , 23 A.3d 1032 (2011). 2 29th, the trial court conducted the remanded Grazier hearing and ruled that the defendant's request to proceed pro se was knowing, intelligent and voluntary and as such Appellant was permitted to self-represent with his court -appointed attorney to remain as back-up counsel. | 1 | 3 |
Commonwealth v. Fordgreen2 sentences2015See Henkel, supra; Ford, supra. Additionally, PCRA counsel stated at the Grazier hearing that he was actively working on Melo’s appellate brief. -5- J-S73041-14 address it. 2015See Henkel, supra; Ford, supra. Additionally, PCRA counsel stated at the Grazier hearing that he was actively working on Melo’s appellate brief. -5- J-S73041-14 address it. | 1 | 2 |
Commonwealth v. Garanggreen1 sentence2025See Commonwealth v. Garang, 9 A.3d 237, 240 (Pa. Super. 2010). | 1 | 1 |
Commonwealth v. Kenneygreen2 sentences2025“An indigent petitioner has the right to appointment of counsel to assist in prosecuting a first PCRA petition,” a right which extends to “each stage of post-conviction review.” Commonwealth v. Kenney, 732 A.2d 1161, 1164 (Pa. 1999); see also Pa.R.Crim.P. 907(C). 2025“An indigent petitioner has the right to appointment of counsel to assist in prosecuting a first PCRA petition,” a right which extends to “each stage of post-conviction review.” Commonwealth v. Kenney, 732 A.2d 1161, 1164 (Pa. 1999); see also Pa.R.Crim.P. 907(C). | 1 | 1 |
Commonwealth v. Coopergreen2 sentences2025See Cooper, 27 A.3d at 1004 . 7 On June 27, 2025, Appellant filed an application for relief alleging ineffective assistance of appellate counsel and requesting a Grazier hearing. 2025See Cooper, 27 A.3d at 1004 . 7 On June 27, 2025, Appellant filed an application for relief alleging ineffective assistance of appellate counsel and requesting a Grazier hearing. | 1 | 1 |
Commonwealth v. Phillipsgreen2 sentences2025See Trial Ct. Order, 6/11/18 (stating that “[f]ollowing a colloquy on the record, the court finds that [Appellant’s] waiver of [his] right to counsel is knowing, voluntary and intelligent” (some formatting altered)). “[O]nce a defendant has made a competent waiver of counsel, that waiver remains in effect through all subsequent proceedings in that case absent a substantial change in circumstances.” Commonwealth v. Phillips, 141 A.3d 512, 521 (Pa. Super. 2016). 2025See Trial Ct. Order, 6/11/18 (stating that “[f]ollowing a colloquy on the record, the court finds that [Appellant’s] waiver of [his] right to counsel is knowing, voluntary and intelligent” (some formatting altered)). “[O]nce a defendant has made a competent waiver of counsel, that waiver remains in effect through all subsequent proceedings in that case absent a substantial change in circumstances.” Commonwealth v. Phillips, 141 A.3d 512, 521 (Pa. Super. 2016). | 1 | 1 |
Commonwealth v. Hartgreen2 sentences2025See Commonwealth v. Grazier, 713 A.2d 81 (Pa. 1998). -7- J-A05013-25 generally Commonwealth v. Hart, 911 A.2d 939, 942 (Pa. Super. 2006) (“The purpose for appointing counsel for a first-time petitioner, even where the petition appears to be untimely filed, is for the petitioner to attempt to establish an exception to the one-year time limitation.”). 2025See Commonwealth v. Grazier, 713 A.2d 81 (Pa. 1998). -7- J-A05013-25 generally Commonwealth v. Hart, 911 A.2d 939, 942 (Pa. Super. 2006) (“The purpose for appointing counsel for a first-time petitioner, even where the petition appears to be untimely filed, is for the petitioner to attempt to establish an exception to the one-year time limitation.”). | 1 | 1 |
Commonwealth v. Pagangreen2 sentences2024Commonwealth v. Pagan, 950 A.2d 270, 292-93 (Pa. 2008). 2024Commonwealth v. Pagan, 950 A.2d 270, 292-93 (Pa. 2008). | 1 | 1 |
Commonwealth v. Bennettgreen2 sentences2024If Appellant desires representation, the PCRA court shall determine whether Appellant remains indigent, and if so, appoint “appropriate counsel.” See Commonwealth v. Bennett, 930 A.2d 1264, 1274 (Pa. 2007). 2024If Appellant desires representation, the PCRA court shall determine whether Appellant remains indigent, and if so, appoint “appropriate counsel.” See Commonwealth v. Bennett, 930 A.2d 1264, 1274 (Pa. 2007). | 1 | 1 |
| Commonwealth v. Cherrygreen | 1 | 1 |
Commonwealth v. Dennisgreen2 sentences2024“The matter of whether 8 If Appellant desires to proceed pro se and is permitted to do so after a Grazier hearing, this Court will accept Appellant’s pro se concise statement (and the PCRA court’s PCO) in conducting review following remand. -15- J-S37011-23 the trial court possesses the authority to impose a particular sentence is a matter of legality.” Commonwealth v. Dennis, 164 A.3d 503, 510 (Pa. Super. 2017) (citation omitted). 2024“The matter of whether 8 If Appellant desires to proceed pro se and is permitted to do so after a Grazier hearing, this Court will accept Appellant’s pro se concise statement (and the PCRA court’s PCO) in conducting review following remand. -15- J-S37011-23 the trial court possesses the authority to impose a particular sentence is a matter of legality.” Commonwealth v. Dennis, 164 A.3d 503, 510 (Pa. Super. 2017) (citation omitted). | 1 | 1 |
Commonwealth v. Pantaliongreen1 sentence2024Commonwealth v. Pantalion, 957 A.2d 1267, 1271 (Pa. Super. 2008). | 1 | 1 |
| Commonwealth v. Taylorgreen | 1 | 1 |
| Commonwealth v. Davidogreen | 1 | 1 |
| Commonwealth v. Jonesgreen | 1 | 1 |
| Commonwealth v. Stewardgreen | 1 | 1 |
| Commonwealth v. Rogersgreen | 1 | 1 |
| Commonwealth v. Kleingreen | 1 | 1 |
| Brady v. Marylandgreen | 1 | 1 |
| Commonwealth v. Bryantgreen | 1 | 1 |
| Com. v. Vinson, J.green | 1 | 1 |
| Commonwealth v. Kelseygreen | 1 | 1 |
| Commonwealth v. Hoodgreen | 1 | 1 |
| Commonwealth, Aplt. v. Moody, K.green | 1 | 1 |
| Commonwealth v. Smithgreen | 1 | 1 |
| Com. v. Shaw, P.green | 1 | 1 |
| Commonwealth v. Pilcheskygreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Commonwealth v. Finley
green
2 sentences2020Appellant’s Brief at 5.4 When reviewing the propriety of an order denying PCRA relief, we consider the record “in the light most favorable to the prevailing party at the PCRA level.” Commonwealth v. Stultz, 114 A.3d 865 , 872 (Pa. Super. ____________________________________________ 4 Due to the procedural posture of this case, i.e., the PCRA court granted counsel’s motion to withdraw and permitted Appellant to proceed pro se after a Grazier hearing, we need not conduct a traditional Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988), and Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (en 2020Appellant’s Brief at 5.4 When reviewing the propriety of an order denying PCRA relief, we consider the record “in the light most favorable to the prevailing party at the PCRA level.” Commonwealth v. Stultz, 114 A.3d 865 , 872 (Pa. Super. ____________________________________________ 4 Due to the procedural posture of this case, i.e., the PCRA court granted counsel’s motion to withdraw and permitted Appellant to proceed pro se after a Grazier hearing, we need not conduct a traditional Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988), and Commonwealth v. Finley, 550 A.2d 213 (Pa. Super. 1988) (en | 9 | 2015–2023 |
Anders v. California
green
2 sentences2023After Attorney Rapa filed a statement of intent to file an Anders “no merit” brief,4 Lane sought and received a second Grazier hearing and received permission to proceed ____________________________________________ 3 See Commonwealth v. Grazier, 713 A.2d 81 (Pa. 1988). 4 See Anders v. California, 386 U.S. 738 (1967). 2021Counsel entered an appearance in this Court and filed a petition to withdraw and brief pursuant to Anders v. California, 386 U.S. 738 (1967). | 3 | 2014–2023 |
Commonwealth, Aplt. v. Walker, T.
green
2 sentences2019Accordingly, for No. 6870-12 only, we vacate the order of July 19, 2018, and remand to the PCRA court; upon remand, the PCRA court must appoint counsel to represent Appellant or hold a Grazier hearing. -3- J-S46041-19 No. 4370-13 On June 1, 2018, in Commonwealth v. Walker, 185 A.3d 969 (Pa. 2018), the Supreme Court of Pennsylvania held that the common practice of filing a single notice of appeal from an order involving more than one docket would no longer be tolerated, because the practice violates Pa.R.A.P. 341, which requires the filing of “separate appeals from an order that resolves issues 2019Accordingly, for No. 6870-12 only, we vacate the order of July 19, 2018, and remand to the PCRA court; upon remand, the PCRA court must appoint counsel to represent Appellant or hold a Grazier hearing. -3- J-S46041-19 No. 4370-13 On June 1, 2018, in Commonwealth v. Walker, 185 A.3d 969 (Pa. 2018), the Supreme Court of Pennsylvania held that the common practice of filing a single notice of appeal from an order involving more than one docket would no longer be tolerated, because the practice violates Pa.R.A.P. 341, which requires the filing of “separate appeals from an order that resolves issues | 2 | 2019–2020 |
Commonwealth v. Robinson
green
2 sentences2020The following exchange took place: APPELLANT: Well, I thought that this hearing was to see if [Attorney DeStefano] was ineffective. ____________________________________________ grounds Commonwealth v. Robinson, 931 A.2d 15 (Pa.Super. 2007) (same). 2020The following exchange took place: APPELLANT: Well, I thought that this hearing was to see if [Attorney DeStefano] was ineffective. ____________________________________________ grounds Commonwealth v. Robinson, 931 A.2d 15 (Pa.Super. 2007) (same). | 2 | 2020–2020 |
Erie Insurance Exchange v. Moore
green
2 sentences2019However, although, again, “[o]missions like these significantly impair our ability to consider an appeal[,]” Erie, 175 A.3d at 1006 , both Appellant and the Commonwealth agree that the hearing occurred and the order was entered, and we will thus accept the procedural history as presented in the PCRA court’s opinion. 2019However, although, again, “[o]missions like these significantly impair our ability to consider an appeal[,]” Erie, 175 A.3d at 1006 , both Appellant and the Commonwealth agree that the hearing occurred and the order was entered, and we will thus accept the procedural history as presented in the PCRA court’s opinion. | 2 | 2019–2019 |
Commonwealth v. Fransen
green
2 sentences2015Id. at 159 . 2015Id. at 159 . | 2 | 2012–2015 |
| Commonwealth v. Koehler green | 1 | 2023–2023 |
| Com. v. Burton green | 1 | 2021–2021 |
| Com. v. Felder, H. green | 1 | 2021–2021 |
| Commonwealth v. Rykard green | 1 | 2021–2021 |
| McMullen v. Com. of Pa. green | 1 | 2020–2020 |
| Commonwealth v. Dukeman green | 1 | 2020–2020 |
| Miranda v. Arizona green | 1 | 2019–2019 |
| Commonwealth v. Colon-Plaza green | 1 | 2019–2019 |
| Berg v. Nationwide Mutual Insurance green | 1 | 2019–2019 |
| Commonwealth v. Wolfe green | 1 | 2019–2019 |
| Commonwealth v. Tejada green | 1 | 2019–2019 |
| Commonwealth v. El green | 1 | 2018–2018 |
| Commonwealth v. Evans green | 1 | 2018–2018 |
| Commonwealth v. Brady green | 1 | 2017–2017 |
| Com. v. Edwards neutral | 1 | 2017–2017 |
| Commonwealth v. McDonough green | 1 | 2016–2016 |
| Commonwealth v. Houtz green | 1 | 2016–2016 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.