may find waiver in Pennsylvania

2026Rule 1925 further provides that “[i]ssues … not raised in accordance with the provisions of this paragraph (b)(4) are waived.” Pa.R.A.P. 1925(b)(4)(vii); Hansley, 24 A.3d at 415 (“[I]f a concise statement is too vague, the court may find waiver.”).

2024Thus, if a concise statement is too vague, the court may find waiver.” Commonwealth v. Hansley, 24 A.3d 410, 415 (Pa. Super. 2011) (citations omitted).

2022See In re A.B., 63 A.3d 345, 350 (Pa. Super. 2013) (explaining that a rule 1925(b) statement must be specific enough for the trial court to identify and address the issue and this Court may find waiver where a concise statement is too vague).

2019See In re A.B., 63 A.3d 345, 350 (Pa. Super. 2013) (stating that this Court may find waiver where a concise statement is too vague).

2025Commonwealth v. Scott, 212 A.3d 1094, 1112 (Pa. Super. 2019) (internal citations, quotations, and original brackets omitted).

2022Thus, if a concise statement is too vague, the court may find waiver." Commonwealth v. Scott, 212 A.3d 1094, 1112 (Pa. Super. 2019) (citation omitted), appeal denied, 222 A.3d 3 83 (Pa. 2019).

2020Commonwealth v. Reeves, 907 A.2d 1, 2 (Pa. Super. 2006).

2019We have explained, “[i]f a Rule 1925(b) statement is too vague, the trial judge may find waiver and disregard any argument.” Commonwealth v. Reeves, 907 A.2d 1, 2 (Pa. Super. 2006); see also Commonwealth v. Hansley, 24 A.3d 410, 415 (Pa. Super. 2011) (stating that “if a concise statement is too vague, the court may find waiver”).

2021Thus, if a concise statement is too vague, the court may find waiver. - 16 - J-A25042-20 Commonwealth v. Hansley, 24 A.3d 410, 415 (Pa.Super. 2011), appeal denied, 613 Pa. 642 , 32 A.3d 1275 (2011) (internal citations and quotation marks omitted).

2020“Thus, if a concise statement is too vague, the court may find waiver.” Id.

2020Thus, when a Defendant fails to preperly plead all three prongs, or, having done so, to develop the claim, the Defendant is not entitled to relief and the court may find the claim waived for lack of development See Commonwealth v. Steele, 961 A.2d 786 (Pa. 2008). 5 68_0pinion and Order.pd Additionally, trial counsel has broad discretion to determine the course of defense tactics and strategy.

2020Pa.R.A.P. 2119(a)-(b); See Commonwealth v. Steele, 961 A.2d 786 (Pa. 2008) (holding when petitioner fails to properly plead or develop a prong, the petitioner is not entitled to relief and the court may find the claim waived for lack of development).

2023A Rule 1925(b) statement that is too vague to afford the court an opportunity to identify the issues raised on appeal “is the functional equivalent of no statement at all.” Commonwealth v. Cannon, 954 A.2d 1222, 1228 (Pa. Super. 2008); see also Commonwealth v. Hansley, 24 A.3d 410, 415 (Pa. Super. 2011) (“if a concise statement is too vague, the court may find waiver.”).

2022A Rule 1925(b) statement that is too vague to allow the trial court an opportunity to identify the issues raised on appeal “is the functional equivalent of no statement at all.” Commonwealth v. Cannon, 954 A.2d 1222, 1228 (Pa. Super. 2008); see also Commonwealth v. Hansley, 24 A.3d 410, 415 (Pa. Super. 2011) (“if a concise statement is too vague, the court may find waiver.”).

2016See id.; see also Commonwealth v. Hansley, 24 A.3d 410, 415 (Pa. Super. 2011) (holding that this Court may find waiver where a concise statement is too vague); Commonwealth v. Dowling, 778 A.2d 683, 686 (Pa. Super. 2001) (holding that, when a court has to guess what issues an appellant is 8 To the extent that Robinson claimed, in his pro se Response to the PCRA court’s Rule 907 Notice, that PCRA counsel was ineffective for failing to raise this issue of trial counsel’s ineffectiveness, Robinson’s claim on appeal appears to be limited to trial counsel’s ineffectiveness.

2016See Hansley, 24 A.3d at 415 (holding that this Court may find waiver where a concise statement is too vague); Dowling, 778 A.2d at 686 (holding that, when a court has to guess what issues an appellant is appealing, that is not enough for meaningful review).

2019Hansley, at 415 (citation omitted); see also Lineberger v. Wyeth, 894 A.2d 141 , 148–49 (Pa.Super. 2006) (holding that where an appellant's Rule 1925(b) statement generally stated that the trial court had erred when it granted the appellee’s summary judgment motion and did not reiterate the arguments the appellant had raised in her opposition to the motion for summary judgment, the appellant’s statement was so vague that she had failed to preserve any issue for appellate review and, consequently, waived her issues on appeal).

2006Unlike the appellant in Lineberger , who at least narrowed her con cise statement to focus on a specific element of her cause of action, i.e. “proximate cause,” see 894 A.2d at 144 , the Wells’s Rule 1925(b) statement is unfocused and indefinite, including all of the multiple elements of their claims. ¶ 12 In situations like this, where the Rule 1925(b) statement is obviously vague and abstract, the trial court may find waiver and disregard any argument.

2014See -5- J-A03045-14 Commonwealth v. Hansley, 24 A.3d 410, 415-16 (Pa. Super. 2011), appeal denied, 32 A.3d 1275 (Pa. 2011) ( on appeal waived where he failed to specify claims in his Rule 1925(b) statement); see also Commonwealth v. Castillo, 888 A.2d 775, 776, 780 (Pa. 2005) (reaffirming bright-line waiver rule for Rule 1925 established in Commonwealth v. Lord, 719 A.2d 306 (Pa. 1998), and stating that any issues not raised in Rule 1925(b) statement are waived.).

2014Development Corp. v. Presque Isle Downs, Inc., 88 A.3d 222, 224 (Pa. Super. 2014) (“Our Supreme Court intended the holding in [Commonwealth v.] Lord[, 719 A.2d 306 (Pa. 1998)] to operate as a bright-line rule, such that ‘failure to comply with the minimal requirements of Pa.R.A.P.1925(b) will result in automatic waiver of the issues raised.’”).

2025Rail Corp., 254 A.3d 738, 745-46 (Pa.Super. 2021).

2025Moreover, “it is well-settled that issues not included in an appellant’s … concise statement of errors complained of on appeal are waived.” In re M.Z.T.M.W., 163 A.3d 462, 466 (Pa. Super. 2017) (citation omitted); see also Pa.R.A.P. 1925(b)(4)(vii) (providing that “[i]ssues not included in the Statement … are waived.”); In the Interest of: G.D. v. D.D., 61 A.3d 1031 , 1036 n.3 (Pa. Super. 2013) (stating where a pro se appellant raises an issue in an appellate brief that is not raised in their Pa.R.A.P. 1925(a)(2)(i) statement, this Court may find waiver). - 14 - J-A11012-25 Instantly, Father’s

2023See, e.g., Commonwealth v. Murchinson, 899 A.2d 1159, 1162 (Pa. Super. 2006) (stating that this Court may find waiver pursuant to Pa.R.A.P. 2119(a) based on an appellant’s “failure to develop meaningful argument with specific reference to the record in support of his claims”).

2021See N.T., 6/19/19, at 80-81, 126-128. - 12 - J-S18029-21 Commonwealth v. Stallworth, 781 A.2d 110, 120 (Pa. 2001) (citation omitted).

2021Bd. of Supervisors of Willistown Twp. v. Main Line Gardens, Inc., 638 Pa. 323, 334 , 155 A.3d 39, 45 (2017).

2021Bd. of Supervisors of Willistown Twp. v. Main Line Gardens, Inc., 638 Pa. 323, 334 , 155 A.3d 39, 45 (2017).

2020See also Commonwealth v. Freeman, 128 A.3d 1231, 1248-49 (Pa.Super. 2015) (holding appellant waived his challenge to weight of evidence where his Rule 1925(b) statement failed to offer specific reasons why verdicts were against weight of evidence).

2020Even if waiver did not apply, this appeal would still fail, as we discern no arguable merit to Appellant’s claim of ineffective assistance of VOP counsel. ____________________________________________ 1 In certain limited circumstances, including the actual or constructive denial of counsel, prejudice may be so plain that the cost of litigating the issue of prejudice is unjustified, and a finding of ineffective assistance of counsel per se is warranted.” Commonwealth v. Rosado, 150 A.3d 425, 429 (Pa. 2016).

2020See Commonwealth v. Fowler, 670 A.2d 153 (Pa. Super. 1996); Commonwealth v. Mizell, 425 A.2d 424 (Pa. 1981).

2017Applying the foregoing to Defendant's sufficiency claim it should be deemed waived because Defendant failed to articulate which elements of the crimes of which he was convicted the Commonwealth failed to establish. "[W]hen challenging the sufficiency of the evidence on appeal, the [a]ppellant's [Rule] 1925 statement must 'specify the element or elements upon which the evidence was insufficient' in order to preserve the issue for appeal." Commonwealth v. Gibbs, 981 A.2d 274, 281 (Pa. Super. 2009), appeal denied, 3 A.3d 670 (Pa. 2010) (quoting Commonwealth v. Williams, 959 A.2d 1252, 1257 (Pa. S

2017Applying the foregoing to Defendant's sufficiency claim it should be deemed waived because Defendant failed to articulate which elements of the crimes of which he was convicted the Commonwealth failed to establish. "[W]hen challenging the sufficiency of the evidence on appeal, the [a]ppellant's [Rule] 1925 statement must 'specify the element or elements upon which the evidence was insufficient' in order to preserve the issue for appeal." Commonwealth v. Gibbs, 981 A.2d 274, 281 (Pa. Super. 2009), appeal denied, 3 A.3d 670 (Pa. 2010) (quoting Commonwealth v. Williams, 959 A.2d 1252, 1257 (Pa. S

2015“Even if the trial court correctly guesses the issues [the appellant] raises on appeal and writes an opinion pursuant to that supposition, the issue is still waived.” Commonwealth v. Heggins, 809 A.2d 908, 911 (Pa.Super. 2002), appeal denied, 573 Pa. 703 , 827 A.2d 430 (2003).

2015See also, Commonwealth v. Lemon, 804 A.2d 34, 38 (Pa. Super. 2002) (“[W]hen an appellant fails to identify in a vague Pa.R.A.P. 1925(b) statement the specific issues he/she wants to raise on appeal, the issue is waived, even if the trial court guesses correctly and addresses the issue in its Pa.R.A.P. 1925(a) opinion.”).

2014See -5- J-A03045-14 Commonwealth v. Hansley, 24 A.3d 410, 415-16 (Pa. Super. 2011), appeal denied, 32 A.3d 1275 (Pa. 2011) ( on appeal waived where he failed to specify claims in his Rule 1925(b) statement); see also Commonwealth v. Castillo, 888 A.2d 775, 776, 780 (Pa. 2005) (reaffirming bright-line waiver rule for Rule 1925 established in Commonwealth v. Lord, 719 A.2d 306 (Pa. 1998), and stating that any issues not raised in Rule 1925(b) statement are waived.).

2014Development Corp. v. Presque Isle Downs, Inc., 88 A.3d 222, 224 (Pa. Super. 2014) (“Our Supreme Court intended the holding in [Commonwealth v.] Lord[, 719 A.2d 306 (Pa. 1998)] to operate as a bright-line rule, such that ‘failure to comply with the minimal requirements of Pa.R.A.P.1925(b) will result in automatic waiver of the issues raised.’”).