comprehensive analysis in Pennsylvania

2025“Further, this type of extravagant 1925(b) statement makes it all but impossible for the trial court to provide a comprehensive analysis of the issues.” Jones v. Jones, 878 A.2d 86, 90 (Pa. Super. 2005).

2024“Further, this type of extravagant 1925(b) statement makes it all but impossible for the trial court to provide a comprehensive analysis of the issues.” Jones v. Jones, 878 A.2d 86, 90 (Pa. Super. 2005).

2024Tours, 939 A.2d 343, 346 (Pa.Super. 2007), aff’d, 602 Pa. 147 , 977 A.2d 1170 (2009). “[T]his type of extravagant 1925(b) statement makes it all but impossible for the trial court to provide a comprehensive analysis of the issues.” Id. (citation omitted).

2024Voluminous Rule 1925(b) statements “make[] it all but impossible for the trial court to provide a comprehensive analysis of the issues.” Tucker, 939 A.2d at 346 (citation omitted).

2025“The court must make a comprehensive inquiry into whether proper parental care is immediately available or what type of care [the parent] could provide in the future.” Id.

2023“The court must make a comprehensive inquiry into whether proper parental care is immediately available or what type of care [the parent] could provide in the future.” Id.

2026See Gagnon v. Scarpelli, 411 U.S. 778, 782 (1973); Commonwealth v. Davis, 336 A.2d 616, 620 (Pa. Super. 1975); Commonwealth v. Ferguson, 761 A.2d 613, 617 (Pa. Super. 2000).

2026See Gagnon v. Scarpelli, 411 U.S. 778, 782 (1973); Commonwealth v. Davis, 336 A.2d 616, 620 (Pa. Super. 1975); Commonwealth v. Ferguson, 761 A.2d 613, 617 (Pa. Super. 2000).

2020See In re R.W.J., 826 A.2d 10, 12 (Pa. Super. 2003); In re G.T., supra at 873; see also Interest of S. M.

2020See In re R.W.J., 826 A.2d 10, 12 (Pa. Super. 2003); In re G.T., supra at 873; see also Interest of S. M.

2026See Gagnon v. Scarpelli, 411 U.S. 778, 782 (1973); Commonwealth v. Davis, 336 A.2d 616, 620 (Pa. Super. 1975); Commonwealth v. Ferguson, 761 A.2d 613, 617 (Pa. Super. 2000).

2026See Gagnon v. Scarpelli, 411 U.S. 778, 782 (1973); Commonwealth v. Davis, 336 A.2d 616, 620 (Pa. Super. 1975); Commonwealth v. Ferguson, 761 A.2d 613, 617 (Pa. Super. 2000).

2020See Ray, 134 A.3d at 1114 ; Tucker, 939 A.2d at 346 (“this type of extravagant 1925(b) statement makes it all but impossible for the trial court to provide a comprehensive analysis of the issues”).

2020“When a court has to guess what issues an appellant is appealing, that is not enough for meaningful review.” Id. (citation omitted). “[T]his type of extravagant 1925(b) statement makes it all but impossible for the trial court to provide a comprehensive analysis of the issues.” Jones v. Jones, 878 A.2d 86, 90 (Pa. Super. 2005).

2026See Gagnon v. Scarpelli, 411 U.S. 778, 782 (1973); Commonwealth v. Davis, 336 A.2d 616, 620 (Pa. Super. 1975); Commonwealth v. Ferguson, 761 A.2d 613, 617 (Pa. Super. 2000).

2026See Gagnon v. Scarpelli, 411 U.S. 778, 782 (1973); Commonwealth v. Davis, 336 A.2d 616, 620 (Pa. Super. 1975); Commonwealth v. Ferguson, 761 A.2d 613, 617 (Pa. Super. 2000).

2021See McGavitt v. Guttman Realty Co., 909 A.2d 1, 4 (Pa. Super. 2006) (declining to waive the appellant’s issues on appeal where, despite a lengthy Rule 1925(b) statement containing superfluous discussion, the trial court was not precluded from conducting a comprehensive analysis of the issues raised). -6- J-A13003-21 Instantly, Father failed to include a statement of questions involved in his brief, as required by Pa.R.A.P. 2116(a).3 Rule 2116(a) “is to be considered in the highest degree mandatory, admitting of no exception; ordinarily no point will be considered which is not set forth in the

2007See Pennsy Supply, Inc. v. Mumma, 921 A.2d 1184 , 1197 *60 (Pa.Super.2007) (holding that a seven-page Rule 1925(b) statement, although containing unnecessary and superfluous language largely directed at answering the questions on appeal, was not so vague as to preclude a clear understanding of the issues raised); McGavitt v. Guttman Realty Co., 909 A.2d 1, 3-4 (Pa.Super.2006) (holding that a six-page Rule 1925(b) statement, although containing superfluous discussion, sufficiently set forth the appellant’s four issues, all of which would have fit on a single page, and thus did not preclude the

2018Bd., 144 Pa. Cmwlth. 374, 379, 601 A.2d 875, 877 (1992) (“[I]t is difficult to extract a comprehensive analysis to be used whenever preemption of local taxation is claimed.”); BRIGHT, 27 SUMM.

2018Bd. , 144 Pa. Cmwlth. 374, 379, 601 A.2d 875 , 877 (1992) ("[I]t is difficult to extract a comprehensive analysis to be used whenever preemption of local taxation is claimed."); Bright , 27 Summ.

2007“Further, this type of extravagant 1925(b) statement makes it all but impossible for the trial court to provide a comprehensive analysis of the issues.” Jones v. Jones, 878 A.2d 86, 90 (Pa.Super.2005). ¶ 8 In the case sub judice, we conclude Appellants have engaged in misconduct when they “attempted to overwhelm the trial court by filing [a] Rule 1925(b) Statement ... that contained a multitude of issues that [Appellants] did not intend to raise and/or could not raise before this Court.” Kanter, 866 A.2d at 402 .

2006We noted, in *4 addition, that although the trial court had attempted to respond to the issues raised in an opinion 85 pages long, it was, nonetheless, “unable to provide a comprehensive analysis of the issues[J” Id. at 401 .

2007We note that “[t]o ensure a proper resolution of [a dependency petition], separate counsel should represent the child at the dependency hearing, and the hearing judge should conduct a comprehensive inquiry by receiving evidence from both interested and disinterested witnesses and should support his decision in an opinion in which he discusses and ana lyzes the evidence folly.” In Interest of Pernishek, 268 Pa.Super. 447 , 408 A.2d 872, 877 (1979).

2007We note that “[t]o ensure a proper resolution of [a dependency petition], separate counsel should represent the child at the dependency hearing, and the hearing judge should conduct a comprehensive inquiry by receiving evidence from both interested and disinterested witnesses and should support his decision in an opinion in which he discusses and ana lyzes the evidence folly.” In Interest of Pernishek, 268 Pa.Super. 447 , 408 A.2d 872, 877 (1979).

2025Id. at 1150-51 (citations, original brackets, and some quotation marks omitted); see also Jones v. Jones, 878 A.2d 86, 90-91 (Pa. Super. 2005) (appellant’s twenty-nine issues written in narrative form made it impossible -4- J-S04045-25 to discern from Rule 1925(b) statement which claims actually identified issues and which provided unnecessary background information resulting in waiver).

2023Id. (citations, quotation marks, and brackets omitted).

2025See J.R., 333 A.3d at 452; see also N.S., 237 A.3d at 552-53 . - 22 -

2025In re J.R., 333 A.3d 446 , 452-53 (Pa. Super. 2025) (per curiam) (citation omitted); see also N.S., 237 A.3d at 552 (holding that “[n]either the 10-page transcript of the permanency review hearing, nor the trial court’s 3-page opinion, exhibits the comprehensive inquiry required in a removal case, or explains why removal of [the child] from [the] mother’s custody promotes [the child’s] best interests or welfare” (citations omitted and some formatting altered)).

2024“Issues not . . . raised in accordance with the provisions of this paragraph . . . are waived.” Id. at 1925(b)(4)(vii); see also In re Estate of Daubert, 757 A.2d 962, 963 (Pa. Super. 2000) (“[w]hen an appellant fails adequately to identify in a concise manner the issues sought to be pursued on appeal, the trial court is impeded in its preparation of a legal analysis which is pertinent to those issues.”); see also Jones v. Jones, 878 A.2d 86, 90 (Pa. Super. 2005) (finding that a Rule 1925(b) statement wherein the appellant raised 29 issues was “extravagant” and “makes it all but impossible for

2021See McGavitt v. Guttman Realty Co., 909 A.2d 1, 4 (Pa. Super. 2006) (declining to waive the appellant’s issues on appeal where, despite a lengthy Rule 1925(b) statement containing superfluous discussion, the trial court was not precluded from conducting a comprehensive analysis of the issues raised). -6- J-A13003-21 Instantly, Father failed to include a statement of questions involved in his brief, as required by Pa.R.A.P. 2116(a).3 Rule 2116(a) “is to be considered in the highest degree mandatory, admitting of no exception; ordinarily no point will be considered which is not set forth in the

2021See McGavitt v. Guttman Realty Co., 909 A.2d 1, 4 (Pa. Super. 2006) (declining to waive the appellant’s issues on appeal where, despite a lengthy Rule 1925(b) statement containing superfluous discussion, the trial court was not precluded from conducting a comprehensive analysis of the issues raised). -6- J-A13003-21 Instantly, Father failed to include a statement of questions involved in his brief, as required by Pa.R.A.P. 2116(a).3 Rule 2116(a) “is to be considered in the highest degree mandatory, admitting of no exception; ordinarily no point will be considered which is not set forth in the

2020Further, as we held in Krebs v. United Refining Co., 893 A.2d 776, 797 (Pa.Super. 2006), a failure to preserve issues by raising them both in the concise statement of errors complained of on appeal and statement of questions involved portion of the brief on appeal results in a waiver of those issues.

2020East Allegheny School District v. Secretary of Education, 603 A.2d 713, 718 (Pa. Cmwlth. 1992).