undeveloped claim (Pennsylvania) · Go Syfert
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undeveloped claim in Pennsylvania

31 Pennsylvania opinions name it 2 courts 1997–2025 12 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.

Followed or applied (22)

CaseFollowedCited
Commonwealth v. Braceygreen
pa · 2001 · cited in 3 Pennsylvania opinions naming this issue, 2005–2005
2 sentences

2005See Commonwealth v. Bracey, 568 Pa. 264 , 795 A.2d 935 , 940 n. 4 (2001) (noting that the mere tacking on of a sentence stating that all prior counsel were ineffective for failing to raise underlying claims of error does not satisfy Appellant’s burden of establishing that he is entitled to post conviction relief on ineffective assistance of counsel claim.) Appellant also raises a number of claims arising from the penalty phase.

2005See Commonwealth v. Bracey, 568 Pa. 264 , 795 A.2d 935 , 940 n. 4 (2001) (noting that the mere tacking on of a sentence stating that all prior counsel were ineffective for failing to raise underlying claims of error does not satisfy Appellant’s burden of establishing that he is entitled to post conviction relief on ineffective assistance of counsel claim.) Appellant also raises a number of claims arising from the penalty phase.

33
Commonwealth v. Briggsgreen
pa · 2011 · cited in 2 Pennsylvania opinions naming this issue, 2013–2022
2 sentences

2022See Commonwealth v. Briggs, 12 A.3d 291 , 326 n.34 (Pa. 2011) (concluding that an undeveloped claim is waived).

2022See Commonwealth v. Briggs, 12 A.3d 291 , 326 n.34 (Pa. 2011) (concluding that an undeveloped claim is waived).

22
Commonwealth v. Johnsongreen
pa · 2009 · cited in 2 Pennsylvania opinions naming this issue, 2022–2022
2 sentences

2022When “an appellate brief fails to provide any discussion of a claim with citation to relevant authority or fails to develop the issue in any other meaningful fashion capable of review, that claim is waived.” Commonwealth v. Johnson, 985 A.2d 915, 924 (Pa. 2009) (citing, inter alia, Pa.R.A.P. 2119(a)); see also Commonwealth v. Russell, 209 A.3d 419 , 429–30 (Pa. Super. 2019) (explaining that this Court will not make an appellant’s arguments and finding waiver of an undeveloped claim).

2022When “an appellate brief fails to provide any discussion of a claim with citation to relevant authority or fails to develop the issue in any other meaningful fashion capable of review, that claim is waived.” Commonwealth v. Johnson, 985 A.2d 915, 924 (Pa. 2009) (citing, inter alia, Pa.R.A.P. 2119(a)); see also Commonwealth v. Russell, 209 A.3d 419 , 429–30 (Pa. Super. 2019) (explaining that this Court will not make an appellant's arguments and finding waiver of an undeveloped claim).

22
Commonwealth v. Russellgreen
pasuperct · 2019 · cited in 2 Pennsylvania opinions naming this issue, 2022–2022
2 sentences

2022When “an appellate brief fails to provide any discussion of a claim with citation to relevant authority or fails to develop the issue in any other meaningful fashion capable of review, that claim is waived.” Commonwealth v. Johnson, 985 A.2d 915, 924 (Pa. 2009) (citing, inter alia, Pa.R.A.P. 2119(a)); see also Commonwealth v. Russell, 209 A.3d 419 , 429–30 (Pa. Super. 2019) (explaining that this Court will not make an appellant’s arguments and finding waiver of an undeveloped claim).

2022When “an appellate brief fails to provide any discussion of a claim with citation to relevant authority or fails to develop the issue in any other meaningful fashion capable of review, that claim is waived.” Commonwealth v. Johnson, 985 A.2d 915, 924 (Pa. 2009) (citing, inter alia, Pa.R.A.P. 2119(a)); see also Commonwealth v. Russell, 209 A.3d 419 , 429–30 (Pa. Super. 2019) (explaining that this Court will not make an appellant's arguments and finding waiver of an undeveloped claim).

22
Commonwealth v. Beshoregreen
pasuperct · 2007 · cited in 2 Pennsylvania opinions naming this issue, 2021–2021
2 sentences

2021See Commonwealth v. Beshore, 916 A.2d 1128, 1140 (Pa. Super. 2007) (en banc). - 12 - J-A14008-21 Lastly, Appellants do not dispute the trial court’s finding that the change in the access point benefits them.

2021See Commonwealth v. Beshore, 916 A.2d 1128, 1140 (Pa. Super. 2007) (en banc).

22
Commonwealth v. McGillgreen
pa · 2003 · cited in 2 Pennsylvania opinions naming this issue, 2006–2006
2 sentences

2006This opinion preceded the Court’s acknowledgement in Commonwealth v. McGill, 574 Pa. 574 , 832 A.2d 1014 (2003), that the Court's requirements pertaining to development of a claim of ineffective stewardship on the part of appellate counsel were not clear, and the associated holding that an appropriate response to an undeveloped claim in cases preceding McGill was a remand to provide an opportunity for adequate development under clarified standards.

2006This opinion preceded the Court’s acknowledgement in Commonwealth v. McGill, 574 Pa. 574 , 832 A.2d 1014 (2003), that the Court's requirements pertaining to development of a claim of ineffective stewardship on the part of appellate counsel were not clear, and the associated holding that an appropriate response to an undeveloped claim in cases preceding McGill was a remand to provide an opportunity for adequate development under clarified standards.

22
Commonwealth v. Gorbygreen
pa · 1991 · cited in 2 Pennsylvania opinions naming this issue, 1997–1997
2 sentences

1997See, e.g., Commonwealth v. Gorby, 527 Pa. 98, 112-13 , 588 A.2d 902, 909 (1991) (evidence of flight relevant and admissible to establish an inference of guilt). .In an undeveloped claim presented in a footnote, Appellant indicates that defense counsel did not object to every question the prosecutor asked of Permint.

1997See, e.g., Commonwealth v. Gorby, 527 Pa. 98, 112-13 , 588 A.2d 902, 909 (1991) (evidence of flight relevant and admissible to establish an inference of guilt). .In an undeveloped claim presented in a footnote, Appellant indicates that defense counsel did not object to every question the prosecutor asked of Permint.

22
Commonwealth v. Tielschgreen
pasuperct · 2007 · cited in 2 Pennsylvania opinions naming this issue, 2023–2025
2 sentences

2025Tielsch, supra. In sum, as none of Richardson’s multiple claims on appeal have merit, we affirm the PCRA court’s order denying him post-conviction relief.

2023See Commonwealth v. Tielsch, 934 A.2d 81, 93 (Pa. Super. 2007) (refusing to consider an undeveloped claim). -9- J-S33037-22 years to 103 year[s’] state time incarceration” during its initial colloquy.9 See N.T., 9/11/18, at 13.

12
Commonwealth v. Claytongreen
pa · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024See Commonwealth v. Clayton, 816 A.2d 217, 221 (Pa. 2002) (“it is a well settled principle of appellate jurisprudence that undeveloped claims are waived and unreviewable on appeal”).

11
In Re: M.Z.T.M.W., a minor, Appeal of: M.W.green
pasuperct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024See M.Z.T.M.W., 163 A.3d at 465-66 .

11
Wolf, B. v. Santiago, M.green
pasuperct · 2020 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See Wolf v. Santiago, 230 A.3d 394, 401 (Pa. Super. 2020).

11
Commonwealth v. Wholaver, E., Aplt.green
pa · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022See Wholaver, 177 A.3d at 160 (“The Rules of Appellate Procedure require appellants to support their arguments with pertinent discussion and citation to authority.”) (citing Pa.R.A.P. 2119(a)).

11
Commonwealth v. Spotzgreen
pa · 2011 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019If Appellant 4 See Commonwealth v. Spotz, 18 A.3d 244, 323 (Pa. 2011) (holding that the appellant's undeveloped claim was unreviewable and, therefore, waived). -6 J -S17007-19 intended to raise this claim in the statement of the questions involved, it is not apparent to this Court.

11
Commonwealth v. Jonesgreen
pa · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019Accordingly, this Court finds no further support in the record for the instant undeveloped claim of ineffectiveness of trial counsel and, as such, the claim must fail. [Footnote 26] Com[monwealth] v. Jones, 811 A.2d 994, 1003 (Pa. 2002). [Footnote 27] N.T. 8/30/12 at []131.

11
Commonwealth v. Christinegreen
pa · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
1 sentence

2017See Commonwealth v. Arrington, 624 Pa. 506 , 86 A.3d 831 (2014). 6 Although not included in his “Statement of Questions Involved,” Appellant presents the following undeveloped claim in the argument portion of his brief: CHALLENGE TO DISCRETIONARY ASPECT OF SENTENCE Trial court imposed an illegal and unconstitutional sentence which is unwaivable.

11
Commonwealth v. Arringtongreen
pa · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
1 sentence

2017See Commonwealth v. Arrington, 624 Pa. 506 , 86 A.3d 831 (2014). 6 Although not included in his “Statement of Questions Involved,” Appellant presents the following undeveloped claim in the argument portion of his brief: CHALLENGE TO DISCRETIONARY ASPECT OF SENTENCE Trial court imposed an illegal and unconstitutional sentence which is unwaivable.

11
Connor v. Crozer Keystone Health Systemgreen
pasuperct · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015See Connor, 832 A.2d at 1119 . - 11 - J.

11
Commonwealth v. Waltergreen
pa · 2009 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
2 sentences

2015See Commonwealth v. Walter, 600 Pa. 392 , 966 A.2d 560, 566 (2009) (holding claims waived for failure to develop them).

2015See Commonwealth v. Walter, 600 Pa. 392 , 966 A.2d 560, 566 (2009) (holding claims waived for failure to develop them).

11
Commonwealth v. Piercegreen
pa · 2001 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
1 sentence

2014See Pierce, supra at 213 .

11
Commonwealth v. Padillagreen
pa · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
1 sentence

2014Commonwealth v. Padilla, 80 A.3d 1238 , 1255 n.16 (Pa. 2013) (“an undeveloped claim is waived”).

11
Fletcher-Harlee Corp. v. Szymanskigreen
pasuperct · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2013–2013
1 sentence

2013See Fletcher-Harlee Corp. v. Szymanski, 936 A.2d 87, 103 (Pa.Super.2007) (deeming a claim that is undeveloped and unsupported by relevant authority to be waived); Pa.R.A.P. 2119(a).

11
Commonwealth v. Blountgreen
pa · 1994 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999
2 sentences

1999See Commonwealth v. Blount, 538 Pa. 156, 174 , 647 A.2d 199, 209 (1994) (fact that Appellant may believe that further explanation by the court would be beneficial does not render charge defective.) 6.

1999See Commonwealth v. Blount, 538 Pa. 156, 174 , 647 A.2d 199, 209 (1994) (fact that Appellant may believe that further explanation by the court would be beneficial does not render charge defective.) 6.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Brady v. Maryland green
scotus · 1963
2 sentences

2024Additionally, in his Rule 1925(b) statement, Baumgardner again raised his newly-discovered fact claim, which involves an alleged violation of Brady v. Maryland, 373 U.S. 83 (1963).

2008Next, the court considered Appellant’s various claims that the Commonwealth withheld potentially exculpatory evidence *172 in violation of the United States Supreme Court’s decision in Brady v. Maryland, 373 U.S. 83, 87 , 83 S.Ct. 1194 , 10 L.Ed.2d 215 (1963) (holding that “the suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution”), and that counsel was ineffective for failing to pursue these claims at the appropriate ti

22008–2024
Commonwealth v. May green
pa · 2006
1 sentence

2019May, 898 A.2d at 565 . 3 To the extent Hildalgo-Lopez attempts to assert an undeveloped claim that trial counsel was ineffective for failing to call witnesses, he is likewise entitled to no relief.

12019–2019

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 9711 (11) PA § 42 Pa. Cons. Stat. § 9543 (8) PA § 42 Pa. Cons. Stat. § 9541 (7) PA § 18 Pa. Cons. Stat. § 2502 (5) PA § 42 Pa. Cons. Stat. § 9545 (5) PA § 42 Pa. Cons. Stat. § 9546 (5) PA § 42 Pa. Cons. Stat. § 9544 (4)

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.

Where else courts name it

PA 31 (1997–2025) CA 13 (2006–2025) NM 12 (2019–2025) IL 3 (1977–1979) OR 3 (2009–2018) WI 3 (2017–2025) WA 2 (2019–2019)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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