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

12 Pennsylvania opinions name it 3 courts 1977–2026 4 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 (7)

CaseFollowedCited
Com. v. Carter, P.green
pasuperct · 2024 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026Commonwealth v. Carter, 320 A.3d 140, 143-46 (Pa. Super. 2024) (citations and footnotes omitted).

11
Commonwealth v. Shawgreen
pa · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026Specifically, the Pennsylvania Supreme Court has explained: “In determining whether a foreign state’s statute is equivalent to a Pennsylvania crime under Section 9714 [of the Judicial Code], . . . the court must consider ‘the elements of the foreign offense in terms of classification of the conduct proscribed, its definition of the offense, and the requirements for culpability.’” Commonwealth v. Northrip, 985 A.2d 734, 740 (Pa. 2009) (quoting Commonwealth v. Shaw, 744 A.2d 739, 743 (Pa. 2000) (citation omitted) (superseded by statute)).

11
Commonwealth v. Dempstergreen
pasuperct · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See id.; see also Moury, supra. Nevertheless, we review the merits of Carter’s claim as part of our independent review of the record.15 See Dempster, supra. Our review of the record reveals that, at sentencing, the trial court considered testimony ____________________________________________ 15 We note that Attorney Fiorillo has failed to include a Rule 2119(f) statement in the Anders brief; however, this omission is not an impediment to our review in this case.

11
Commonwealth v. Mourygreen
pasuperct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See id.; see also Moury, supra. Nevertheless, we review the merits of Carter’s claim as part of our independent review of the record.15 See Dempster, supra. Our review of the record reveals that, at sentencing, the trial court considered testimony ____________________________________________ 15 We note that Attorney Fiorillo has failed to include a Rule 2119(f) statement in the Anders brief; however, this omission is not an impediment to our review in this case.

11
Commonwealth v. Austingreen
pasuperct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See Commonwealth v. Austin, 66 A.3d 798, 807-08 (Pa. Super. 2013).

11
Commonwealth v. Zeiglergreen
pasuperct · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See Commonwealth v. Zeigler, 112 A.3d 656, 661 (Pa. Super. 2015) (where counsel filed Anders brief, this Court reviewed discretionary sentencing claim even absent Rule 2119(f) statement). - 16 - J-S32040-22 and letters from one of Carter’s daughters, Megan Truscott, Carter’s lifelong best friend, Linda Olano, the pastor at Carter’s church, Jeremy Smallwood, and Ashley Stumhofer, a fellow inmate.

11
Commonwealth v. Cartergreen
pa · 1995 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020See Commonwealth v. Carter, 656 A.2d 463, 466 (Pa. 1995) (Carter’s plea knowing and voluntary were, even though he was not told sentences could run consecutively, he was informed of maximum sentence for each count and his sentence was less than the maximum).

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 (7)

CaseCitedYears
Commonwealth v. Banks green
pasuperct · 2017
2 sentences

2020Commonwealth v. Banks, 165 A.3d 976 , 980- 81 (Pa. Super. 2017).

2020Commonwealth v. Banks, 165 A.3d 976 , 980- 81 (Pa. Super. 2017).

22020–2020
Commonwealth v. Carter green
pasuperct · 2014
2 sentences

2017Commonwealth v. Carter, 105 A.3d 765 , 768–69 (Pa.Super. 2014) (en banc) (footnote omitted). -7- J-S40008-17 In Carter, this Court reversed the trial court’s grant of Carter’s motion to suppress, finding his Fourth Amendment rights were not violated when the arresting officer seized Carter and conducted a limited pat-down after observing him in a high crime area at night with a weighed and angled bulge in his coat pocket.

2015Cf. id. at 767 .

22015–2017
Commonwealth v. Carter green
pa · 1967
2 sentences

1977The Pennsylvania rule requiring the prosecution to make the names and whereabouts of material eyewitnesses available to the defense . . . requires reversal of the instant conviction.” (Emphasis in original.) The Carter rule requiring disclosure of the names and whereabouts of material eyewitnesses was based on an . . awareness that the testimonial perspective of police officers is conditioned by the ‘often competitive enterprise of ferreting out crime.’ ” Id. 427 Pa. at 61 , 233 A.2d at 288 .

1977The Pennsylvania rule requiring the prosecution to make the names and whereabouts of material eyewitnesses available to the defense . . . requires reversal of the instant conviction.” (Emphasis in original.) The Carter rule requiring disclosure of the names and whereabouts of material eyewitnesses was based on an . . awareness that the testimonial perspective of police officers is conditioned by the ‘often competitive enterprise of ferreting out crime.’ ” Id. 427 Pa. at 61 , 233 A.2d at 288 .

21977–2015
Commonwealth v. Northrip green
pa · 2009
1 sentence

2026Specifically, the Pennsylvania Supreme Court has explained: “In determining whether a foreign state’s statute is equivalent to a Pennsylvania crime under Section 9714 [of the Judicial Code], . . . the court must consider ‘the elements of the foreign offense in terms of classification of the conduct proscribed, its definition of the offense, and the requirements for culpability.’” Commonwealth v. Northrip, 985 A.2d 734, 740 (Pa. 2009) (quoting Commonwealth v. Shaw, 744 A.2d 739, 743 (Pa. 2000) (citation omitted) (superseded by statute)).

12026–2026
Falasco v. Pa. Bd. of Prob. & Parole green
pacommwct · 1987
1 sentence

2024Falasco, 521 A.2d at 995 ; Gregory, 530 A.2d at 1050 . 5 Initially, we reject Carter’s claim alleging an illegal sentence rooted in an erroneous birthdate and social security number.

12024–2024
Gregory v. Pa. Bd. of Prob. & Parole green
pacommwct · 1987
1 sentence

2024Falasco, 521 A.2d at 995 ; Gregory, 530 A.2d at 1050 . 5 Initially, we reject Carter’s claim alleging an illegal sentence rooted in an erroneous birthdate and social security number.

12024–2024
Commonwealth v. Steele green
pa · 2008
2 sentences

2020In fact, much of the juror’s letter, and Lampe’s argument, focuses on the alleged statements made by the jurors themselves, which testimony is not eligible for the Carter exception to the “no impeachment rule.” See Steele, supra. Moreover, juror #9’s proposed testimony is not - 29 - J-A15016-20 limited to outside influences, see id., as that juror proposed to testify that she and the other jurors were “unaware they could go home that evening without first rendering a verdict.” Appellant’s Brief, at 57.

2020In fact, much of the juror’s letter, and Lampe’s argument, focuses on the alleged statements made by the jurors themselves, which testimony is not eligible for the Carter exception to the “no impeachment rule.” See Steele, supra. Moreover, juror #9’s proposed testimony is not - 29 - J-A15016-20 limited to outside influences, see id., as that juror proposed to testify that she and the other jurors were “unaware they could go home that evening without first rendering a verdict.” Appellant’s Brief, at 57.

12020–2020

Where else courts name it

NJ 51 (2004–2026) TX 35 (1984–2026) GA 29 (1976–2025) CA 23 (1970–2026) IL 20 (1989–2024) LA 18 (1979–2019) OH 18 (2004–2025) FL 17 (1983–2022) PA 12 (1977–2026) IN 12 (1994–2024) WA 8 (1995–2018) MI 7 (1971–2021) MO 7 (1980–2017) DC 7 (1992–2024) UT 6 (1995–2025) IA 5 (2005–2024) AL 5 (1992–2026) ID 5 (1983–2020) WI 5 (2002–2025) VA 5 (1993–2024) MS 5 (2004–2014) CO 4 (1966–2024) MD 4 (1972–2016) AR 3 (2001–2015) ME 3 (1990–2025) MA 3 (1994–2009) MN 3 (1996–1997) KS 3 (1966–2015) TN 3 (1953–2022) NY 2 (2010–2019) DE 2 (2014–2017) NV 2 (1982–1985) KY 2 (1937–2023) NE 2 (1995–2015)

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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