petition invoking a timeliness exception (Pennsylvania) · Go Syfert
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petition invoking a timeliness exception in Pennsylvania

18 Pennsylvania opinions name it 1 courts 2015–2026 11 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 (8)

CaseFollowedCited
Schuylkill Township v. Pennsylvania Builders Associationgreen
pa · 2008 · cited in 3 Pennsylvania opinions naming this issue, 2021–2021
2 sentences

2021“We emphasize that it is the petitioner who bears the burden to allege and prove that one of the timeliness exceptions applies.” Commonwealth v. Marshall, 596 Pa. 587 , 947 A.2d 714, 719 (2008) (citation omitted). ____________________________________________ 3 42 Pa.C.S.A. § 9545(b)(2) previously provided that a petition invoking a timeliness exception was required to be filed within sixty days of the date the claim could first have been presented.

2021“We emphasize that it is the petitioner who bears the burden to allege and prove that one of the timeliness exceptions applies.” Commonwealth v. Marshall, 596 Pa. 587 , 947 A.2d 714, 719 (2008) (citation omitted). ____________________________________________ 3 42 Pa.C.S.A. § 9545(b)(2) previously provided that a petition invoking a timeliness exception was required to be filed within sixty days of the date the claim could first have been presented.

33
Commonwealth v. Gamboa-Taylorgreen
pa · 2000 · cited in 2 Pennsylvania opinions naming this issue, 2020–2020
2 sentences

2020See Commonwealth v. Gamboa-Taylor, 562 Pa. 70 , 753 A.2d 780 (2000).

2020See Commonwealth v. Gamboa-Taylor, 562 Pa. 70 , 753 A.2d 780 (2000).

22
Commonwealth v. Fahygreen
pa · 1999 · cited in 3 Pennsylvania opinions naming this issue, 2015–2021
2 sentences

2021Commonwealth v. Fahy, 737 A.2d 214, 222 (Pa. 1999).

2016Additionally, a petition invoking a timeliness exception pursuant to the statute must “be filed within 60 days of the date the claim could have been presented.” Id. at § 9545(b)(2). -5- J-S13011-16 consider Resch’s petition and properly dismissed it.4 Jones, supra; Fahy, supra. Order affirmed.

13
Com. v. Pearson, M.green
pasuperct · 2024 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026Moreover, “[p]ost conviction DNA testing does not directly create an exception to § 9545’s one-year time bar.” Commonwealth v. Pearson, 320 A.3d 1224, 1229 (Pa. Super. 2024) (citation omitted).

11
Thach v. Abington Memorial Hospitalgreen
pa · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026To meet the newly-discovered facts timeliness exception set forth in Section 9545(b)(1)(ii), a petitioner must “demonstrate he did not know the -4- J-S05017-26 facts upon which he based his petition and could not have learned those facts earlier by the exercise of due diligence.” Commonwealth v. Brown, 111 A.3d 171, 176 (Pa.Super. 2015), appeal denied, 633 Pa. 761 , 125 A.3d 1197 (2015).

11
Commonwealth v. Staton, A., Aplt.green
pa · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025Nicholas asserts that his PCRA petition is timely under the newly discovered fact exception to the timeliness requirement. 2 To satisfy the newly discovered fact exception “the petitioner must establish only that (1) the facts upon which the claim was predicated were unknown and (2) they could not have been ascertained by the exercise of due diligence.” Commonwealth v. Staton, 184 A.3d 949, 955 (Pa. 2018) (citation omitted).

11
Commonwealth v. Smithgreen
pasuperct · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023Furthermore, we consider: “Although a Brady violation may fall within the governmental interference exception, the petitioner must plead and prove that the failure to previously raise these claims was the result of interference by government officials, and that the information could not have been obtained earlier with the exercise of due diligence.” Smith, 194 A.3d at 133 (citation omitted). - 10 - J-S33022-23 Appellant avers the PCRA court erred in finding his petition was untimely and in dismissing his petition without a hearing.

11
Williams v. Madenspachergreen
pa · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
1 sentence

2018In Burton, the Pennsylvania Supreme Court held that “the presumption that information which is of public record cannot be deemed ‘unknown’ for purposes of subsection 9545(b)(1)(ii) [of the PCRA] does not apply to pro se prisoner petitioners.” Burton, 158 A.3d at 638 (emphasis in original).

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 (9)

CaseCitedYears
Commonwealth v. Marshall green
pa · 2008
2 sentences

2021“We emphasize that it is the petitioner who bears the burden to allege and prove that one of the timeliness exceptions applies.” Commonwealth v. Marshall, 596 Pa. 587 , 947 A.2d 714, 719 (2008) (citation omitted). ____________________________________________ 3 42 Pa.C.S.A. § 9545(b)(2) previously provided that a petition invoking a timeliness exception was required to be filed within sixty days of the date the claim could first have been presented.

2021“We emphasize that it is the petitioner who bears the burden to allege and prove that one of the timeliness exceptions applies.” Commonwealth v. Marshall, 596 Pa. 587 , 947 A.2d 714, 719 (2008) (citation omitted). ____________________________________________ 3 42 Pa.C.S.A. § 9545(b)(2) previously provided that a petition invoking a timeliness exception was required to be filed within sixty days of the date the claim could first have been presented.

32021–2021
Commonwealth v. Carter green
pa · 2012
2 sentences

2016Additionally, a petition invoking a timeliness exception pursuant to the statute must “be filed within 60 days of the date the claim could have been presented.” Id. at § 9545(b)(2). -5- J-S13011-16 consider Resch’s petition and properly dismissed it.4 Jones, supra; Fahy, supra. Order affirmed.

2015Jones, supra; Fahy, supra. Order affirmed.

22015–2016
Com. v. Barnhart green
pa · 2015
1 sentence

2026To meet the newly-discovered facts timeliness exception set forth in Section 9545(b)(1)(ii), a petitioner must “demonstrate he did not know the -4- J-S05017-26 facts upon which he based his petition and could not have learned those facts earlier by the exercise of due diligence.” Commonwealth v. Brown, 111 A.3d 171, 176 (Pa.Super. 2015), appeal denied, 633 Pa. 761 , 125 A.3d 1197 (2015).

12026–2026
Abeln v. Eidelman green
pa · 2015
1 sentence

2026To meet the newly-discovered facts timeliness exception set forth in Section 9545(b)(1)(ii), a petitioner must “demonstrate he did not know the -4- J-S05017-26 facts upon which he based his petition and could not have learned those facts earlier by the exercise of due diligence.” Commonwealth v. Brown, 111 A.3d 171, 176 (Pa.Super. 2015), appeal denied, 633 Pa. 761 , 125 A.3d 1197 (2015).

12026–2026
Com. v. Larkin, R. green
pasuperct · 2020
1 sentence

2024Finally, “[a]sserted exceptions to the time restrictions for the PCRA must be included in the petition, and may not be raised for the first time on appeal.” Commonwealth v. Larkin, 235 A.3d 350 , 356 (Pa.Super. 2020) (en banc).

12024–2024
Com. v. Vinson, J. green
pasuperct · 2021
1 sentence

2022However, effective December 24, 2018, the legislature amended Subsection 9545(b)(2)” to increase that time limit to one year.” Commonwealth v. Vinson, 249 A.3d 1197 , 1204 n.5 (Pa. Super. 2021).

12022–2022
Johnson v. United States green
scotus · 2015
1 sentence

2021The amendment, inter alia, substituted “within one year” for “within 60 days” in 42 Pa.C.S. § 9545(b)(2); and Section 3 of Act 2018-146 provided that this amendment “shall apply only to claims arising one year before the effective date of this section or thereafter.” -7- J-A02011-21 The constitutional right at issue herein was allegedly recognized in Johnson, supra, which was decided on June 26, 2015.5 The PCRA court correctly examined whether Appellant’s assertion that the United States Supreme Court created a new constitutional right in Johnson would satisfy the timeliness exception for an a

12021–2021
Miller v. Alabama green
scotus · 2012
1 sentence

2019Indeed, in his petition, Stanley contended he was entitled to review pursuant to the PCRA’s new constitutional right exception at Section 9545(b)(1)(iii), based upon Miller v. Alabama, 567 U.S. 460 (2012), and related case law.8 See Post-Conviction Relief Act Petition, 8/23/2012, at 3-7. ____________________________________________ 7 We note that until recently, a petition invoking a timeliness exception had to be filed within 60 days of the date the claim could have been presented.

12019–2019
Commonwealth v. Neiman green
pa · 2013
1 sentence

2015Durant’s claim invokes the newly-recognized constitutional right exception in section 9545(b)(1)(iii); Durant bases his claim upon the holding in Commonwealth v. Neiman, 84 A.3d 603 (Pa. 2013), filed on December 16, 2013.

12015–2015

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 9545 (10) PA § 18 Pa. Cons. Stat. § 2502 (3)

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.

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