bright-line mandatory instruction in Pennsylvania

2023In Walker, 185 A.3d at 976-77 , our Supreme Court characterized Rule 341(a) as “a bright-line mandatory instruction to practitioners to file separate notices of appeal” for each docket.

2023In Walker, 185 A.3d at 976-77 ,15 our Supreme Court interpreted Rule 341(a) as setting forth “a bright-line mandatory instruction to practitioners to file separate notices of appeal” for each docket.

2020The failure to do so requires the appellate court to quash the appeal.” Id. at 976-77 ; see Commonwealth v. Williams, 206 A.3d 573 (Pa. Super. 2019) (quashing pro se appeal that listed four trial court docket numbers on the notice of appeal); Commonwealth v. Luciani, 201 A.3d 802 , 805 n.2 (Pa. Super. 2018) (despite joinder of charges filed at two separate dockets for the purposes of trial, appellants are still required to file separate notices of appeal under Walker).

2019See Commonwealth v. Luciani, 201 A.3d 802 , 805 n.2 (Pa.Super. 2018) (recognizing that, despite the fact that charges filed at two separate lower court docket numbers are joined for trial, under Walker, supra, appellants are required to file separate notices of appeal).

2020The failure to do so requires the appellate court to quash the appeal.” Id. at 976-77 ; see Commonwealth v. Williams, 206 A.3d 573 (Pa. Super. 2019) (quashing pro se appeal that listed four trial court docket numbers on the notice of appeal); Commonwealth v. Luciani, 201 A.3d 802 , 805 n.2 (Pa. Super. 2018) (despite joinder of charges filed at two separate dockets for the purposes of trial, appellants are still required to file separate notices of appeal under Walker).

2019See Commonwealth v. Williams, 206 A.3d 573 (Pa.Super. 2019) (quashing a pro se appeal that listed four trial court docket numbers on the notice of appeal); Commonwealth v. Luciani, 201 A.3d 802 , 805 n.2 (Pa.Super. 2018) (recognizing that, despite the fact that charges filed -3- J-S49038-19 at two separate docket numbers are joined for trial, appellants are required to file separate notices of appeal under Walker).

2021However, in Commonwealth v. Larkin, 235 A.3d 350 (Pa. Super. 2020) (en banc), this Court held that we may overlook the requirements set forth in Walker in cases where “a breakdown occurs in the court system, and a defendant is misinformed or misled regarding his appellate rights.” Larkin, 235 A.3d at 354.

2021However, in Commonwealth v. Larkin, 235 A.3d 350 (Pa. Super. 2020) (en banc), this Court held that we may overlook the requirements set forth in Walker in cases where “a breakdown occurs in the court system, and a defendant is misinformed or misled regarding his appellate rights.” Larkin, 235 A.3d at 354.

2020See Commonwealth v. Robinson, 837 A.2d 1157, 1162 (Pa. 2003).

2020Commonwealth v. Nichols, 208 A.3d 1087, 1089-90 (Pa.Super. 2019) (emphasis in original).

2019See Commonwealth v. Williams, 151 A.3d 621, 624 (Pa. Super. 2016) (holding “this Court is required to docket a pro se notice of appeal despite Appellant[’s] being represented by counsel”). 2 The transcript of this hearing is not included in the certified record. 3New counsel was appointed by the trial court via an order dated January 24, 2019. -2- J-S28037-19 that “[w]here … one or more orders resolves [sic] issues arising on more than one docket … separate notices of appeal must be filed.” In Walker, our Supreme Court found that the “Official Note to Rule 341 provides a bright-line mandatory