effectiveness waiver (Pennsylvania) · Go Syfert
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effectiveness waiver in Pennsylvania

14 Pennsylvania opinions name it 6 courts 1954–2022 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 (2)

CaseFollowedCited
Jaffee v. Redmondgreen
scotus · 1996 · cited in 3 Pennsylvania opinions naming this issue, 2006–2020
2 sentences

2020The United States Supreme Court, in rejecting application of an evidentiary exception or balancing test between the interests protected by the State-provided privilege and the fact-finding function of the federal courts, held “[m]aking the promise of confidentiality contingent upon a trial judge’s later evaluation of the relative importance of the patient’s interest in privacy and the evidentiary need for disclosure would eviscerate the effectiveness of the privilege.” Jaffee, 518 U.S. at 17 . unless in either case this privilege is waived upon the trial by the client. 42 Pa.C.S. § 5928. [J-76

2020See Majority Opinion at 12 (quoting Jaffee, 518 U.S. at 17 (stating that “[m]aking the promise of confidentiality contingent upon a trial judge’s later evaluation of the relative importance of the patient’s interest in privacy and the evidentiary need for disclosure would eviscerate the effectiveness of the privilege.”)).

13
State v. Churchgreen
la · 1989 · cited in 1 Pennsylvania opinions naming this issue, 2001–2001
2 sentences

2001Compare State v. Church, 538 So.2d 993 , 997 n. 16 (La.1989) (citing statistical evidence that included roadblocks conducted from December of 1986 to August of 1987 in concluding that the intrusion was of marginal effectiveness).

2001Compare State v. Church, 538 So.2d 993 , 997 n. 16 (La.1989) (citing statistical evidence that included roadblocks conducted from December of 1986 to August of 1987 in concluding that the intrusion was of marginal effectiveness).

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 (19)

CaseCitedYears
Strickland v. Washington green
scotus · 1984
1 sentence

2022Accordingly, he must satisfy the three-part inquiry that Pennsylvania courts have “refined” from Strickland v. Washington, 466 U.S. 668 (1984) by ____________________________________________ 1 It is well-established that a claim that a sentencing court has considered improper or erroneous factors in handing down a sentence does not implicate the legality of the sentence.

12022–2022
Commonwealth v. Marinelli green
pa · 2006
1 sentence

2021Id.

12021–2021
Commonwealth v. Muniz, J., Aplt. red
pa · 2017
1 sentence

2019As Fears, supra, makes clear, it is not the role of this Court to generate Sauers’s arguments for him.8 In his fifth and final claim, Sauers contends that the sexual offender registration portion of his sentence is illegal, based on our Supreme Court’s ruling in Commonwealth v. Muniz, 164 A.3d 1189 (Pa. 2017).

12019–2019
Commonwealth v. Fears green
pa · 2014
1 sentence

2019As Fears, supra, makes clear, it is not the role of this Court to generate Sauers’s arguments for him.8 In his fifth and final claim, Sauers contends that the sexual offender registration portion of his sentence is illegal, based on our Supreme Court’s ruling in Commonwealth v. Muniz, 164 A.3d 1189 (Pa. 2017).

12019–2019
Commonwealth v. Williams green
pa · 2007
2 sentences

2010Commonwealth v. Williams, 594 Pa. 366 , 936 A.2d 12 (2007).

2010Commonwealth v. Williams, 594 Pa. 366 , 936 A.2d 12 (2007).

12010–2010
Upjohn Co. v. United States green
scotus · 1981
2 sentences

2006An uncertain privilege, or one which purports to be certain but results in widely varying applications by the courts, is little better than no privilege at all.’ ” Jaffee v. Redmond, 518 U.S. 1, 17-18 , 116 S.Ct. 1923, 1932 , 135 L.Ed. 2d 337 (1996) (recognizing the psychotherapist-patient privilege for the first time) (quoting Upjohn Co. v. United States, 449 U.S. 383, 393 , 101 S.Ct. 677, 684 , 66 L.Ed.2d 584 (1981)).

2006An uncertain privilege, or one which purports to be certain but results in widely varying applications by the courts, is little better than no privilege at all.’ ” Jaffee v. Redmond, 518 U.S. 1, 17-18 , 116 S.Ct. 1923, 1932 , 135 L.Ed. 2d 337 (1996) (recognizing the psychotherapist-patient privilege for the first time) (quoting Upjohn Co. v. United States, 449 U.S. 383, 393 , 101 S.Ct. 677, 684 , 66 L.Ed.2d 584 (1981)).

12006–2006
Estate of Franks v. Allstate Insurance green
pamd · 1995
1 sentence

2000In Estate of Franks v. Allstate Insurance Co., 895 F. Supp. 77 (M.D.

12000–2000
Commonwealth v. Maloy green
pa · 1970
2 sentences

1983Commonwealth v. Maloy, 438 Pa. 261 , 264 A.2d 697 (1970).

1983Commonwealth v. Maloy, 438 Pa. 261 , 264 A.2d 697 (1970).

11983–1983
Commonwealth v. Taylor green
pa · 1978
2 sentences

1983The Pennsylvania Supreme Court in Commonwealth v. Taylor, 483 Pa. 60 , 394 A.2d 538 (1978), summarized the principles pertinent to a determination of the effectiveness of a waiver of the right to appeal by withdrawal of previously filed post-verdict motions: A person has the right to a direct appeal, but may waive this right.

1983The Pennsylvania Supreme Court in Commonwealth v. Taylor, 483 Pa. 60 , 394 A.2d 538 (1978), summarized the principles pertinent to a determination of the effectiveness of a waiver of the right to appeal by withdrawal of previously filed post-verdict motions: A person has the right to a direct appeal, but may waive this right.

11983–1983
Commonwealth v. Gilmore green
pa · 1975
2 sentences

1977Therefore, since appellant’s trial counsel attacked the confession on the general ground of voluntariness and knowledgeableness, and failed to focus upon his immaturity in assessing the waiver’s effectiveness as suggested in Roane , the latter issue is not preserved for appeal. 2 Commonwealth v. Branham, 467 Pa. 605 , 359 A.2d 766 (1976); Commonwealth v. Gilmore, 464 Pa. 464 , 347 A.2d 305 (1975); Commonwealth v. Mitchell, 464 Pa. 117 , 346 A.2d 48 (1975).

1977Therefore, since appellant’s trial counsel attacked the confession on the general ground of voluntariness and knowledgeableness, and failed to focus upon his immaturity in assessing the waiver’s effectiveness as suggested in Roane , the latter issue is not preserved for appeal. 2 Commonwealth v. Branham, 467 Pa. 605 , 359 A.2d 766 (1976); Commonwealth v. Gilmore, 464 Pa. 464 , 347 A.2d 305 (1975); Commonwealth v. Mitchell, 464 Pa. 117 , 346 A.2d 48 (1975).

11977–1977
Commonwealth v. Green green
pa · 1975
2 sentences

1977Commonwealth v. Johnson, 467 Pa. 146 , 354 A.2d 886 (1976); Commonwealth v. Green, 464 Pa. 557 , 347 A.2d 682 (1975); Commonwealth v. Camm, 443 Pa. 253 , 277 A.2d 325 (1971); cert. denied, 405 U.S. 1046 , 92 S.Ct. 1320 , 31 L.Ed.2d 589 (1972); see also Rule 323(j) of the Pennsylvania Rules of Criminal Procedure. .

1977Commonwealth v. Johnson, 467 Pa. 146 , 354 A.2d 886 (1976); Commonwealth v. Green, 464 Pa. 557 , 347 A.2d 682 (1975); Commonwealth v. Camm, 443 Pa. 253 , 277 A.2d 325 (1971); cert. denied, 405 U.S. 1046 , 92 S.Ct. 1320 , 31 L.Ed.2d 589 (1972); see also Rule 323(j) of the Pennsylvania Rules of Criminal Procedure. .

11977–1977
Miranda v. Arizona green
scotus · 1966
2 sentences

1977Id. at 476 , 86 S.Ct. at 1629 . 4 We cannot accept the implication of the trial judge’s statement, that the inquiry as to the effectiveness of the waiver of a minor is satisfied because the formal prerequisites have been met, as long as there is reason to question whether the minor, in fact, has comprehended his situation.

1977Id. at 476 , 86 S.Ct. at 1629 . 4 We cannot accept the implication of the trial judge’s statement, that the inquiry as to the effectiveness of the waiver of a minor is satisfied because the formal prerequisites have been met, as long as there is reason to question whether the minor, in fact, has comprehended his situation.

11977–1977
Commonwealth v. Camm green
pa · 1971
2 sentences

1977Commonwealth v. Johnson, 467 Pa. 146 , 354 A.2d 886 (1976); Commonwealth v. Green, 464 Pa. 557 , 347 A.2d 682 (1975); Commonwealth v. Camm, 443 Pa. 253 , 277 A.2d 325 (1971); cert. denied, 405 U.S. 1046 , 92 S.Ct. 1320 , 31 L.Ed.2d 589 (1972); see also Rule 323(j) of the Pennsylvania Rules of Criminal Procedure. .

1977Commonwealth v. Johnson, 467 Pa. 146 , 354 A.2d 886 (1976); Commonwealth v. Green, 464 Pa. 557 , 347 A.2d 682 (1975); Commonwealth v. Camm, 443 Pa. 253 , 277 A.2d 325 (1971); cert. denied, 405 U.S. 1046 , 92 S.Ct. 1320 , 31 L.Ed.2d 589 (1972); see also Rule 323(j) of the Pennsylvania Rules of Criminal Procedure. .

11977–1977
Commonwealth v. Mitchell green
pa · 1975
2 sentences

1977Therefore, since appellant’s trial counsel attacked the confession on the general ground of voluntariness and knowledgeableness, and failed to focus upon his immaturity in assessing the waiver’s effectiveness as suggested in Roane , the latter issue is not preserved for appeal. 2 Commonwealth v. Branham, 467 Pa. 605 , 359 A.2d 766 (1976); Commonwealth v. Gilmore, 464 Pa. 464 , 347 A.2d 305 (1975); Commonwealth v. Mitchell, 464 Pa. 117 , 346 A.2d 48 (1975).

1977Therefore, since appellant’s trial counsel attacked the confession on the general ground of voluntariness and knowledgeableness, and failed to focus upon his immaturity in assessing the waiver’s effectiveness as suggested in Roane , the latter issue is not preserved for appeal. 2 Commonwealth v. Branham, 467 Pa. 605 , 359 A.2d 766 (1976); Commonwealth v. Gilmore, 464 Pa. 464 , 347 A.2d 305 (1975); Commonwealth v. Mitchell, 464 Pa. 117 , 346 A.2d 48 (1975).

11977–1977
Commonwealth v. Branham green
pa · 1976
2 sentences

1977Therefore, since appellant’s trial counsel attacked the confession on the general ground of voluntariness and knowledgeableness, and failed to focus upon his immaturity in assessing the waiver’s effectiveness as suggested in Roane , the latter issue is not preserved for appeal. 2 Commonwealth v. Branham, 467 Pa. 605 , 359 A.2d 766 (1976); Commonwealth v. Gilmore, 464 Pa. 464 , 347 A.2d 305 (1975); Commonwealth v. Mitchell, 464 Pa. 117 , 346 A.2d 48 (1975).

1977Therefore, since appellant’s trial counsel attacked the confession on the general ground of voluntariness and knowledgeableness, and failed to focus upon his immaturity in assessing the waiver’s effectiveness as suggested in Roane , the latter issue is not preserved for appeal. 2 Commonwealth v. Branham, 467 Pa. 605 , 359 A.2d 766 (1976); Commonwealth v. Gilmore, 464 Pa. 464 , 347 A.2d 305 (1975); Commonwealth v. Mitchell, 464 Pa. 117 , 346 A.2d 48 (1975).

11977–1977
McConnell v. Anderson green
scotus · 1972
2 sentences

1977Commonwealth v. Johnson, 467 Pa. 146 , 354 A.2d 886 (1976); Commonwealth v. Green, 464 Pa. 557 , 347 A.2d 682 (1975); Commonwealth v. Camm, 443 Pa. 253 , 277 A.2d 325 (1971); cert. denied, 405 U.S. 1046 , 92 S.Ct. 1320 , 31 L.Ed.2d 589 (1972); see also Rule 323(j) of the Pennsylvania Rules of Criminal Procedure. .

1977Commonwealth v. Johnson, 467 Pa. 146 , 354 A.2d 886 (1976); Commonwealth v. Green, 464 Pa. 557 , 347 A.2d 682 (1975); Commonwealth v. Camm, 443 Pa. 253 , 277 A.2d 325 (1971); cert. denied, 405 U.S. 1046 , 92 S.Ct. 1320 , 31 L.Ed.2d 589 (1972); see also Rule 323(j) of the Pennsylvania Rules of Criminal Procedure. [7] Although the trial court did not base the exclusion of this evidence on the factors of legal attenuation and relevancy, we have often held that we may affirm the holding of a lower court if an alternative ground exists.

11977–1977
Manuel v. Salisbury green
scotus · 1972
2 sentences

1977Commonwealth v. Johnson, 467 Pa. 146 , 354 A.2d 886 (1976); Commonwealth v. Green, 464 Pa. 557 , 347 A.2d 682 (1975); Commonwealth v. Camm, 443 Pa. 253 , 277 A.2d 325 (1971); cert. denied, 405 U.S. 1046 , 92 S.Ct. 1320 , 31 L.Ed.2d 589 (1972); see also Rule 323(j) of the Pennsylvania Rules of Criminal Procedure. .

1977Commonwealth v. Johnson, 467 Pa. 146 , 354 A.2d 886 (1976); Commonwealth v. Green, 464 Pa. 557 , 347 A.2d 682 (1975); Commonwealth v. Camm, 443 Pa. 253 , 277 A.2d 325 (1971); cert. denied, 405 U.S. 1046 , 92 S.Ct. 1320 , 31 L.Ed.2d 589 (1972); see also Rule 323(j) of the Pennsylvania Rules of Criminal Procedure. [7] Although the trial court did not base the exclusion of this evidence on the factors of legal attenuation and relevancy, we have often held that we may affirm the holding of a lower court if an alternative ground exists.

11977–1977
Commonwealth v. Johnson green
pa · 1976
2 sentences

1977Commonwealth v. Johnson, 467 Pa. 146 , 354 A.2d 886 (1976); Commonwealth v. Green, 464 Pa. 557 , 347 A.2d 682 (1975); Commonwealth v. Camm, 443 Pa. 253 , 277 A.2d 325 (1971); cert. denied, 405 U.S. 1046 , 92 S.Ct. 1320 , 31 L.Ed.2d 589 (1972); see also Rule 323(j) of the Pennsylvania Rules of Criminal Procedure. .

1977Commonwealth v. Johnson, 467 Pa. 146 , 354 A.2d 886 (1976); Commonwealth v. Green, 464 Pa. 557 , 347 A.2d 682 (1975); Commonwealth v. Camm, 443 Pa. 253 , 277 A.2d 325 (1971); cert. denied, 405 U.S. 1046 , 92 S.Ct. 1320 , 31 L.Ed.2d 589 (1972); see also Rule 323(j) of the Pennsylvania Rules of Criminal Procedure. .

11977–1977
Central Pennsylvania Lumber Co. v. Carter green
pa · 1943
1 sentence

1954The Supreme Court in Central Pennsylvania Lumber Company v. Carter et al., 348 Pa. 429 (1944), discussed the problem of the compulsory nonsuit and agreed that it was res adjudicata as to all contentions which could properly have been passed upon on the first trial.

11954–1954

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 5944 (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

NY 26 (1944–2019) NJ 21 (1911–2025) IL 17 (1975–2025) CA 17 (1969–2026) TX 16 (1985–2025) MI 14 (1976–2024) DE 14 (1981–2026) FL 14 (1972–2021) PA 14 (1954–2022) CO 13 (1986–2018) OH 12 (1991–2013) DC 8 (1976–2022) IA 7 (1966–2010) GA 7 (1993–2008) MD 7 (1972–2014) MA 6 (1981–2006) WA 6 (2008–2020) IN 6 (1997–2011) OK 5 (1938–2018) WI 5 (1987–2021) TN 5 (1958–2016) KS 5 (1974–2015) AZ 5 (1990–2022) LA 4 (1974–1998) AL 4 (1977–2016) ND 3 (1992–1995) OR 3 (1982–1990) VT 3 (1995–2007) CT 3 (2004–2017) MT 2 (1977–1978) AR 2 (1939–1973) MS 2 (2017–2017) MN 2 (1987–2003) NM 2 (2000–2023) SD 2 (1992–2011) UT 2 (1993–2015) NE 2 (2017–2017) RI 2 (1979–2012)

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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