Anderson rule (Pennsylvania) · Go Syfert
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Anderson rule in Pennsylvania

17 Pennsylvania opinions name it 3 courts 1972–2024 3 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 (11)

CaseFollowedCited
Commonwealth v. Fahygreen
pa · 1999 · cited in 2 Pennsylvania opinions naming this issue, 2020–2020
2 sentences

2020See Commonwealth v. Rivera-Figueroa, 174 A.3d 674 (Pa.Super. 2017); see also Commonwealth v. Fahy, 737 A.2d 214, 223 (Pa. 1999) (challenges to legality of sentence “must still first satisfy the PCRA’s time limits or one of the exceptions thereto”).

2020See Commonwealth v. Rivera-Figueroa, 174 A.3d 674 (Pa.Super. 2017); see also Commonwealth v. Fahy, 737 A.2d 214, 223 (Pa. 1999) (challenges to legality of sentence “must still first satisfy the PCRA’s time limits or one of the exceptions thereto”).

22
Commonwealth v. Millergreen
pasuperct · 2014 · cited in 2 Pennsylvania opinions naming this issue, 2020–2020
2 sentences

2020See Commonwealth v. Miller, 102 A.3d 988, 992 (Pa.Super. 2014).

2020See Commonwealth v. Miller, 102 A.3d 988, 992 (Pa.Super. 2014).

22
Commonwealth v. Andersongreen
pa · 1994 · cited in 2 Pennsylvania opinions naming this issue, 2001–2006
2 sentences

2006Anderson, 650 A.2d at 24 . [6] In 2002, the Anderson test was essentially adopted by the General Assembly in 42 Pa. C.S. § 9765, which reads: No crimes shall merge for sentencing purposes unless the crimes arise from a single criminal act and all of the statutory elements of one offense are included in the statutory elements of the other offense.

2006Anderson, 650 A.2d at 24 . [6] In 2002, the Anderson test was essentially adopted by the General Assembly in 42 Pa. C.S. § 9765, which reads: No crimes shall merge for sentencing purposes unless the crimes arise from a single criminal act and all of the statutory elements of one offense are included in the statutory elements of the other offense.

12
Commonwealth v. Rodriguezgreen
pasuperct · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See Commonwealth v. Rodriguez, 141 A.3d 523 , 525 n.4 (Pa. Super. 2016) (concluding that “although Appellant did not comply with our appellate rules, we find that it has not inhibited our ability to review his claim, and decline to find waiver on that basis”). -5- J-S09040-23 Following our review, we discern no error by the PCRA court.

11
Commonwealth v. Mitchellgreen
pasuperct · 2009 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021See Commonwealth v. Mitchell, 986 A.2d 1241 , 1244 n.2 (Pa. Super. 2009) (stating that “[w]hen presented with an Anders brief, this Court may not review the merits of the underlying issues without first passing on the request to withdraw.”).

11
Pennsylvania State Lodge, Fraternal Order of Police v. Commonwealth, Department of Conservation & Natural Resourcesgreen
pacommwct · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016On March 1, 2016, the lower court issued an order transferring the matter to this Court because the Respondents are state employees. 4 When addressing preliminary objections, we are “required to accept as true the well- pled averments set forth in the . . . complaint, and all inferences reasonably deducible therefrom.” Pa. State Lodge, Fraternal Order of Police v. Department of Conservation & Natural Resources, 909 A.2d 413, 415 (Pa. Cmwlth. 2006), aff’d, 924 A.2d 1203 (Pa. 2007). 2 35 to 45 times.

11
Commonwealth v. Williamsgreen
pasuperct · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2007–2007
2 sentences

2007See also Commonwealth v. Williams, 871 A.2d 254, 263 (Pa.Super.2005) (collecting Superior Court cases adopting the Anderson test where a single criminal act is at issue). ¶ 21 We hold that the trial court did not err as a matter of law by imposing separate sentences for the weapons offenses.

2007See also Commonwealth v. Williams, 871 A.2d 254, 263 (Pa.Super.2005) (collecting Superior Court cases adopting the Anderson test where a single criminal act is at issue). ¶ 21 We hold that the trial court did not err as a matter of law by imposing separate sentences for the weapons offenses.

11
Anderson v. Bushong Pontiac Co.green
pa · 1961 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
1 sentence

2005Id. at 775. ¶ 10 With regard to defendant Ugly Duckling, the trial court in the instant case distinguished Anderson by concluding that: the Anderson defendant was on notice that the car could likely be stolen by an incompetent driver for the reason that the keys had been stolen two days earlier, and because minor aged children often played at the lot.

11
Taylor v. Taylorgreen
ind · 1994 · cited in 1 Pennsylvania opinions naming this issue, 2004–2004
1 sentence

2004See, e.g., Taylor v. Taylor, 643 N.E.2d 893 (Ind.1994); McGugart v. Brumback, 77 Wash.2d 441 , 463 P.2d 140 (1969); Banaszkiewicz v. Baun, 359 Mich. 109 , 101 N.W.2d 306 (1960).

11
Commonwealth v. Williamsgreen
pasuperct · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2004–2004
2 sentences

2004See, e.g., Commonwealth v. Williams, 801 A.2d 584 (Pa.Super.2002); Commonwealth v. Ware, 737 A.2d 251 (Pa.Super.1999).

2004See, e.g., Commonwealth v. Williams, 801 A.2d 584 (Pa.Super.2002); Commonwealth v. Ware, 737 A.2d 251 (Pa.Super.1999).

11
Commonwealth v. Felixgreen
pa · 1988 · cited in 1 Pennsylvania opinions naming this issue, 1988–1988
2 sentences

1988See Commonwealth v. Felix, 372 Pa.Super. 145 , 539 A.2d 371 (1988).

1988See Commonwealth v. Felix, 372 Pa.Super. 145 , 539 A.2d 371 (1988).

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 (12)

CaseCitedYears
Anders v. California green
scotus · 1967
2 sentences

2024As discussed above, Robinson’s claims of collateral appeal counsel’s ineffectiveness are easily distinguishable from Greer, supra, and Grazioli, supra. Here, as stated above, appellate counsel filed a rule-compliant ____________________________________________ 7 While Robinson stated Attorney Weisenberger intended to file an “Anderson brief,” we believe he was referring, rather, to Anders v. California, 386 U.S. 738 (1967).

2017Anders, 386 U.S. at 744 ; Rojas, 874 A.2d at 639 .

22017–2024
Commonwealth v. Muniz, J., Aplt. red
pa · 2017
2 sentences

2020Here, Anderson’s claim that he is serving an illegal sentence pursuant to Commonwealth v. Muniz, 164 A.3d 1189 (Pa. 2017), is cognizable under the PCRA.

2020Here, Anderson’s claim that he is serving an illegal sentence pursuant to Commonwealth v. Muniz, 164 A.3d 1189 (Pa. 2017), is cognizable under the PCRA.

22020–2020
Commonwealth v. Rojas green
pasuperct · 2005
1 sentence

2017Anders, 386 U.S. at 744 ; Rojas, 874 A.2d at 639 .

12017–2017
Commonwealth v. Wattley green
pa · 2007
1 sentence

2016On March 1, 2016, the lower court issued an order transferring the matter to this Court because the Respondents are state employees. 4 When addressing preliminary objections, we are “required to accept as true the well- pled averments set forth in the . . . complaint, and all inferences reasonably deducible therefrom.” Pa. State Lodge, Fraternal Order of Police v. Department of Conservation & Natural Resources, 909 A.2d 413, 415 (Pa. Cmwlth. 2006), aff’d, 924 A.2d 1203 (Pa. 2007). 2 35 to 45 times.

12016–2016
Commonwealth v. Walls green
pasuperct · 2012
1 sentence

2015Based on the totality of the circumstances, see Walls, supra, we conclude that in light of the evidence regarding the high crime area, gunshots and Anderson’s flight after grabbing his waistband, the trial court did not err in denying Anderson’s motion to suppress.

12015–2015
McGugart v. Brumback green
wash · 1969
2 sentences

2004See, e.g., Taylor v. Taylor, 643 N.E.2d 893 (Ind.1994); McGugart v. Brumback, 77 Wash.2d 441 , 463 P.2d 140 (1969); Banaszkiewicz v. Baun, 359 Mich. 109 , 101 N.W.2d 306 (1960).

2004See, e.g., Taylor v. Taylor, 643 N.E.2d 893 (Ind.1994); McGugart v. Brumback, 77 Wash.2d 441 , 463 P.2d 140 (1969); Banaszkiewicz v. Baun, 359 Mich. 109 , 101 N.W.2d 306 (1960).

12004–2004
Commonwealth v. Ware green
pasuperct · 1999
2 sentences

2004See, e.g., Commonwealth v. Williams, 801 A.2d 584 (Pa.Super.2002); Commonwealth v. Ware, 737 A.2d 251 (Pa.Super.1999).

2004See, e.g., Commonwealth v. Williams, 801 A.2d 584 (Pa.Super.2002); Commonwealth v. Ware, 737 A.2d 251 (Pa.Super.1999).

12004–2004
Banaszkiewicz v. Baun green
mich · 1960
2 sentences

2004See, e.g., Taylor v. Taylor, 643 N.E.2d 893 (Ind.1994); McGugart v. Brumback, 77 Wash.2d 441 , 463 P.2d 140 (1969); Banaszkiewicz v. Baun, 359 Mich. 109 , 101 N.W.2d 306 (1960).

2004See, e.g., Taylor v. Taylor, 643 N.E.2d 893 (Ind.1994); McGugart v. Brumback, 77 Wash.2d 441 , 463 P.2d 140 (1969); Banaszkiewicz v. Baun, 359 Mich. 109 , 101 N.W.2d 306 (1960).

12004–2004
Commonwealth v. Comer green
pa · 1998
2 sentences

2001Id. at 583 , 650 A.2d at 24 (citation omitted). ¶ 13 To the extent that its analysis in Anderson appeared to focus solely on the statutory elements of each offense, [8] the Court clarified in Commonwealth v. Comer, 552 Pa. 527 , 716 A.2d 593 (1998) that the facts underlying each conviction must be considered as well. [9] Therein, the Court specifically rejected an interpretation of Anderson as permitting a merger analysis based on a comparison of the statutory elements alone "without considering the underlying factual circumstances", stating that such an analysis "ignores the context in which

2001Id. at 583 , 650 A.2d at 24 (citation omitted). ¶ 13 To the extent that its analysis in Anderson appeared to focus solely on the statutory elements of each offense, [8] the Court clarified in Commonwealth v. Comer, 552 Pa. 527 , 716 A.2d 593 (1998) that the facts underlying each conviction must be considered as well. [9] Therein, the Court specifically rejected an interpretation of Anderson as permitting a merger analysis based on a comparison of the statutory elements alone "without considering the underlying factual circumstances", stating that such an analysis "ignores the context in which

12001–2001
Commonwealth v. Krum green
pa · 1987
2 sentences

1988Commonwealth v. Krum, 367 Pa.Super. 511 , 533 A.2d 134 (1987) {en banc).

1988Commonwealth v. Krum, 367 Pa.Super. 511 , 533 A.2d 134 (1987) {en banc).

11988–1988
Bowers v. Workmen's Compensation Appeal Board green
pacommwct · 1983
2 sentences

1988Id. at 516 , 457 A.2d at 176 .

1988Id. at 516 , 457 A.2d at 176 .

11988–1988
Commonwealth v. McBride green
pa · 1970
2 sentences

1972After careful deliberation and reargument, we ruled in Com. v. McBride, 440 Pa. 81 , 269 A. 2d 737 (1970), that a defendant who enters a guilty plea in a “silent record” case tried before Com. ex rel.

1972After careful deliberation and reargument, we ruled in Com. v. McBride, 440 Pa. 81 , 269 A. 2d 737 (1970), that a defendant who enters a guilty plea in a “silent record” case tried before Com. ex rel.

11972–1972

Where else courts name it

CA 210 (1970–2026) TX 60 (1952–2025) WI 25 (1980–2026) MI 22 (1973–2026) OH 22 (1982–2025) FL 19 (1988–2018) GA 18 (1941–2026) PA 17 (1972–2024) WA 17 (1993–2024) IN 17 (1977–2026) IA 17 (1860–2026) MO 15 (1990–2021) MT 10 (1988–2024) UT 9 (1987–2026) DC 8 (1992–2015) DE 8 (2015–2025) AL 7 (1996–2013) MS 7 (2000–2026) KS 7 (1989–2026) AZ 7 (1977–2024) NJ 7 (1991–2021) VA 7 (1992–2023) MN 7 (1989–2019) AK 7 (1981–2014) IL 7 (1991–2026) ID 6 (1991–2025) SD 6 (1996–2025) SC 6 (1998–2026) ND 5 (1980–2004) CO 5 (1995–2026) AR 5 (1893–2024) KY 5 (1969–2025) NE 4 (1990–2024) RI 4 (1973–2012) OK 4 (1994–2007) CT 4 (1990–2020) TN 3 (2000–2020) MD 3 (2008–2017) NY 3 (1999–2025) ME 3 (2001–2020) LA 3 (1987–2002) NM 2 (2000–2021) NC 2 (1944–2006) NH 2 (2006–2007) NV 2 (2013–2019)

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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