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8 Pennsylvania opinions name it 2 courts 2015–2026 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.
| Case | Followed | Cited |
|---|---|---|
Commonwealth v. Graziergreen2 sentences2023On October 4, 2021, [Appellant] filed a supplemental amended PCRA petition…. ____________________________________________ 1 See Commonwealth v. Grazier, 713 A.2d 81, 82 (Pa. 1998) (“When a waiver of the right to counsel is sought at the post-conviction and appellate stages, an on-the-record determination should be made that the waiver is a knowing, intelligent, and voluntary one.”); cf. Pa.R.Crim.P. 904(C) (providing “when an unrepresented defendant satisfies the judge that the defendant is unable to afford or otherwise procure counsel, the judge shall appoint counsel to represent the defendan 2019Id. -3- 2017, the PCRA court conducted a video hearing, and Appellant once again withdrew his request to proceed pro se. | 1 | 3 |
E.K. v. J.R.A.green1 sentence2026See E.K. v. J.R.A., 237 A.3d 509, 522-23 (Pa.Super. 2020) (finding claim waived where appellant failed “to make a contemporaneous specific objection at the PFA hearing”). -8- Regarding the video evidence, the court determined that Wife did not give consent to being recorded, and the admission of the video would be in violation of the Wiretap Act. | 1 | 1 |
Commonwealth v. Eliagreen1 sentence2025See Commonwealth v. Elia, 83 A.3d 254, 264 (Pa. Super. 2013) (an appellate court may affirm a valid judgment based upon any reason appearing in the record). -9- | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Wolff v. McDonnell
green
1 sentence2023While Petitioner understandably wanted to be present to hear Corrections Officer’s testimony and to cross-examine Corrections Officer, and to watch the video with hearing examiner to explain, since there was no audio, this is not constitutionally required by Wolff, 418 U.S. at 567 , and we are constrained by that pronouncement. | 1 | 2023–2023 |
Commonwealth v. Valentine
green
2 sentences2016The PCRA court appointed counsel, and counsel filed an amended petition on June 10, 2015, wherein Appellant argued, inter alia, his sentence was illegal in light of the United States Supreme Court’s decision in Alleyne and this Court’s decision in Commonwealth v. Valentine, 101 A.3d 801 , (Pa. Super. 2014), appeal denied, 124 A.3d 309 (Pa. 2015).8 The PCRA court scheduled a video hearing on Appellant’s amended petition for September 24, 2015, and dismissed the petition the same day. 2016The PCRA court appointed counsel, and counsel filed an amended petition on June 10, 2015, wherein Appellant argued, inter alia, his sentence was illegal in light of the United States Supreme Court’s decision in Alleyne and this Court’s decision in Commonwealth v. Valentine, 101 A.3d 801 , (Pa. Super. 2014), appeal denied, 124 A.3d 309 (Pa. 2015).8 The PCRA court scheduled a video hearing on Appellant’s amended petition for September 24, 2015, and dismissed the petition the same day. | 1 | 2016–2016 |
Gagnon v. Scarpelli
red
1 sentence2015On April 22, 2014, the trial court held a video hearing pursuant to Gagnon v. Scarpelli, 411 U.S. 778 (1973) -2- J-S43011-15 (Gagnon I hearing) to determine if there were probable cause to hold a revocation of probation hearing. | 1 | 2015–2015 |
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.