framework analysis (Pennsylvania) · Go Syfert
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framework analysis in Pennsylvania

17 Pennsylvania opinions name it 5 courts 1978–2025 2 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
Commonwealth v. Elgreen
pa · 2009 · cited in 2 Pennsylvania opinions naming this issue, 2017–2018
2 sentences

2018“In Pennsylvania, Rule of Criminal Procedure 121 sets out a framework for inquiry into a defendant’s request for self-representation.” El, supra at 1162 (citation omitted). “[T]he law is well established that in order to invoke the right of self-representation, the request to proceed pro se must be made timely and not for purposes of delay and must be clear and unequivocal.” Id. at 1163 .

2018“In Pennsylvania, Rule of Criminal Procedure 121 sets out a framework for inquiry into a defendant’s request for self-representation.” El, supra at 1162 (citation omitted). “[T]he law is well established that in order to invoke the right of self-representation, the request to proceed pro se must be made timely and not for purposes of delay and must be clear and unequivocal.” Id. at 1163 .

22
Commonwealth v. Poundsgreen
pa · 1980 · cited in 2 Pennsylvania opinions naming this issue, 1991–2014
2 sentences

2014Commonwealth v. Glover, 500 Pa. 524 , 458 A.2d 935 (1983); Commonwealth v. Pounds, 490 Pa. 621 , 417 A.2d 597, 599 (1980).

2014Commonwealth v. Glover, 500 Pa. 524 , 458 A.2d 935 (1983); Commonwealth v. Pounds, 490 Pa. 621 , 417 A.2d 597, 599 (1980).

22
Stodghill v. Pennsylvania Department of Correctionsgreen
pa · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023Thus, we conclude that Chestnut failed to establish a claim that direct appeal counsel was ineffective per se.11 Lastly, given the possible confusion at which case the PCRA court granted sentencing relief,12 we consider sua sponte the legality of the ____________________________________________ 11 Furthermore, Chestnut’s generic assertions that direct appeal counsel was ineffective with respect to his discretionary aspect and legality of sentence claims do not establish any of the three prongs for assessing trial counsel’s ineffectiveness outside the framework of a claim of ineffectiveness per

11
Commonwealth, Aplt. v. Wolfe, M.green
pa · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023Thus, we conclude that Chestnut failed to establish a claim that direct appeal counsel was ineffective per se.11 Lastly, given the possible confusion at which case the PCRA court granted sentencing relief,12 we consider sua sponte the legality of the ____________________________________________ 11 Furthermore, Chestnut’s generic assertions that direct appeal counsel was ineffective with respect to his discretionary aspect and legality of sentence claims do not establish any of the three prongs for assessing trial counsel’s ineffectiveness outside the framework of a claim of ineffectiveness per

11
United States v. Jamie Edward Byrdgreen
ca11 · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2012–2012
1 sentence

2012See United States v. Byrd, 403 F.3d 1278 , 1283 n. 1 (11th Cir.2005) (noting in past decisions concerning whether to reopen evidence, “we reviewed for an abuse of discretion without providing a framework for our analysis”; concluding Walker factors are “helpful in assessing whether the [trial] court abused its discretion-”).

11
Commonwealth v. Raineygreen
pa · 1995 · cited in 1 Pennsylvania opinions naming this issue, 2002–2002
1 sentence

2002Thus, trial counsel cannot be deemed ineffective for failing to assert such a meritless claim. 656 A.2d at 1334 (citation omitted).

11
Clark v. Community for Creative Non-Violencegreen
scotus · 1984 · cited in 1 Pennsylvania opinions naming this issue, 2001–2001
2 sentences

2001See Clark v. Community for Creative Non-Violence, 468 U.S. 288, 298 , 104 S.Ct. 3065 , 82 L.Ed.2d 221 (1984) (noting that the O’Brien test for validating a regulation of expressive conduct “is little, if any, different from the standard applied to time, place and manner restrictions”).

2001See Clark v. Community for Creative Non-Violence, 468 U.S. 288, 298 , 104 S.Ct. 3065 , 82 L.Ed.2d 221 (1984) (noting that the O’Brien test for validating a regulation of expressive conduct “is little, if any, different from the standard applied to time, place and manner restrictions”).

11
State v. De Simonegreen
nj · 1972 · cited in 1 Pennsylvania opinions naming this issue, 1987–1987
2 sentences

1987However, the framework for this analysis and determination is provided in the well reasoned decision by Weintraub, C.J., in State v. DeSimone, 60 N.J. 319 , 288 A.2d 849 at 850-51 (1972): “On principle, the sufficiency of a warrant to search persons identified only by their presence at a specified place should depend upon the facts.

1987However, the framework for this analysis and determination is provided in the well reasoned decision by Weintraub, C.J., in State v. DeSimone, 60 N.J. 319 , 288 A.2d 849 at 850-51 (1972): “On principle, the sufficiency of a warrant to search persons identified only by their presence at a specified place should depend upon the facts.

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 (10)

CaseCitedYears
Commonwealth v. Glover green
pa · 1983
2 sentences

2014Commonwealth v. Glover, 500 Pa. 524 , 458 A.2d 935 (1983); Commonwealth v. Pounds, 490 Pa. 621 , 417 A.2d 597, 599 (1980).

2014Commonwealth v. Glover, 500 Pa. 524 , 458 A.2d 935 (1983); Commonwealth v. Pounds, 490 Pa. 621 , 417 A.2d 597, 599 (1980).

21991–2014
Faretta v. California green
scotus · 1975
2 sentences

2025Where a defendant knowingly, voluntarily, and intelligently seeks to waive his right to counsel, the trial court, in keeping with Faretta[ v. California, 422 U.S. 806 , 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975)], must allow the individual to proceed pro se.

2025Where a defendant knowingly, voluntarily, and intelligently seeks to waive his right to counsel, the trial court, in keeping with Faretta[ v. California, 422 U.S. 806 , 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975)], must allow the individual to proceed pro se.

12025–2025
City of Philadelphia v. Schaffer green
pacommwct · 2009
1 sentence

2019City of Phila. v. Schaffer, 974 A.2d 509 , 511 n.4 (Pa. Cmwlth. 2009). 2 By way of a framework for our analysis, the redemption statute, in pertinent part, provides: (a) The owner of any property sold under a tax or municipal claim . . . may, except as provided in subsection (c) of this section, redeem the same at any time within nine months from the date of the acknowledgment of the sheriff’s deed therefor, upon payment of the amount bid at such sale; the cost of drawing, acknowledging, and recording the sheriff’s deed; the amount of all taxes and municipal claims, whether not entered as lien

12019–2019
Smith v. Doe green
scotus · 2003
2 sentences

2017Id. at 92 , 123 S.Ct. 1140 .

2017Id. at 92 , 123 S.Ct. 1140 .

12017–2017
Kansas v. Hendricks green
scotus · 1997
2 sentences

2016In Smith, the United States Supreme Court delineated the framework for this inquiry-as follows: We must “ascertain whether the legislature meant the statute to establish ‘civil’ proceedings.” Kansas v. Hendricks, 521 U.S. 346, 361 , 117 S.Ct. 2072 , 138 L.Ed.2d 501 (1997).

2016In Smith, the United States Supreme Court delineated the framework for this inquiry-as follows: We must “ascertain whether the legislature meant the statute to establish ‘civil’ proceedings.” Kansas v. Hendricks, 521 U.S. 346, 361 , 117 S.Ct. 2072 , 138 L.Ed.2d 501 (1997).

12016–2016
Commonwealth v. Brown green
pa · 2009
2 sentences

2016In setting a framework for our analysis, we observed that, “generally speaking, restitution is the requirement that the criminal offender repay, as a condition of his sentence, the victim or society, in money or services.” Brown, 981 A.2d at 895 .

2016Echoing Runion, we emphasized that “the primary purpose of restitution is rehabilitation of the offender.” Id.

12016–2016
Commonwealth v. Glass green
pa · 1991
2 sentences

2014In Commonwealth v. Glass, 526 Pa. 329 , 586 A.2d 369 (1991), our Supreme Court explained that questions regarding delays in sentencing should be analyzed under the same standard that applies to alleged speedy trial violations: This Court has firmly established a framework for analysis of cases where delays in sentencing have implicated rights to a speedy trial under the Sixth Amendment and under Article I, § 9 of the Pennsylvania Constitution.

2014In Commonwealth v. Glass, 526 Pa. 329 , 586 A.2d 369 (1991), our Supreme Court explained that questions regarding delays in sentencing should be analyzed under the same standard that applies to alleged speedy trial violations: This Court has firmly established a framework for analysis of cases where delays in sentencing have implicated rights to a speedy trial under the Sixth Amendment and under Article I, § 9 of the Pennsylvania Constitution.

12014–2014
Mathews v. Eldridge green
scotus · 1976
2 sentences

1997The framework of analysis is set out in Mathews v. Eldridge, 424 U.S. 319 , 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976).

1997The framework of analysis is set out in Mathews v. Eldridge, 424 U.S. 319 , 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976).

11997–1997
Thornburgh v. Lewis green
pa · 1983
2 sentences

1988Thornburgh v. Lewis, 504 Pa. 206 , 470 A.2d 952 (1983); Zemprelli v. Daniels; Sweeney v. Tucker, and we, of course, adhere to its instruction.

1988Thornburgh v. Lewis, 504 Pa. 206 , 470 A.2d 952 (1983); Zemprelli v. Daniels; Sweeney v. Tucker, and we, of course, adhere to its instruction.

11988–1988
Commonwealth v. Conti green
pasuperct · 1975
2 sentences

1978We set out the framework for this inquiry, as regards a nonjury trial, in Commonwealth v. Conti, 236 Pa.Super. 488 , 345 A.2d 238 (1975).

1978We set out the framework for this inquiry, as regards a nonjury trial, in Commonwealth v. Conti, 236 Pa.Super. 488 , 345 A.2d 238 (1975).

11978–1978

Statutes the citing opinions construe

PA § 18 Pa. Cons. Stat. § 3121 (3) PA § 42 Pa. Cons. Stat. § 9541 (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.

Where else courts name it

IA 55 (1990–2023) CA 26 (1966–2025) TX 23 (1990–2025) PA 17 (1978–2025) DC 15 (1978–2025) OR 14 (1982–2026) NY 13 (1976–2025) NJ 13 (1960–2018) IL 12 (1995–2026) MD 11 (1979–2026) FL 11 (1973–2023) OH 10 (1987–2025) CO 10 (1988–2016) WI 9 (1990–2022) MI 7 (1977–2026) LA 7 (1991–2018) MN 7 (1983–2019) CT 7 (1982–2015) NE 6 (2017–2022) IN 6 (1982–2016) NC 5 (1992–2022) DE 5 (1997–2019) VA 4 (2000–2013) TN 4 (2001–2020) WV 4 (1979–2020) AK 4 (1978–2016) MA 4 (1993–2024) KS 4 (2007–2025) HI 4 (1980–2012) KY 3 (1960–2020) ID 3 (1983–2005) NM 3 (2007–2009) AL 3 (2004–2015) UT 3 (2021–2023) AZ 2 (1968–2016) ME 2 (1976–1984) WA 2 (2011–2011) WY 2 (2005–2024) GA 2 (1983–2024) MO 2 (1996–1999) RI 2 (1986–2007) ND 2 (1995–2009)

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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