per se ineffectiveness standard (Pennsylvania) · Go Syfert
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per se ineffectiveness standard in Pennsylvania

7 Pennsylvania opinions name it 1 courts 2012–2022 1 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 (6)

CaseFollowedCited
Commonwealth v. Spotzgreen
pa · 2005 · cited in 2 Pennsylvania opinions naming this issue, 2018–2019
2 sentences

2019See [Commonwealth v.] Spotz, [ 870 A.2d 822, 834 (Pa. 2005)].

2018See Spotz, supra .

22
Commonwealth v. Lantzygreen
pa · 1999 · cited in 2 Pennsylvania opinions naming this issue, 2014–2015
2 sentences

2015Where, as in the instant case, the claim is counsel’s failure to file a direct appeal, Pennsylvania utilizes a per se ineffectiveness test, Commonwealth v. Lantzy, 736 A.2d 564, 571 (Pa. 1999) (“a failure to file or perfect [a direct] appeal results in a denial so fundamental as to constitute prejudice per se”), so long as an appellant establishes that he “requested [counsel to file] an appeal and that counsel disregarded the request.” Commonwealth v. Hudson, 485 A.2d 487, 489 (Pa. Super. 1984).

2014See Commonwealth v. Lantzy, 736 A.2d 564, 571 (Pa. 1999).

22
United States v. Cronicgreen
scotus · 1984 · cited in 2 Pennsylvania opinions naming this issue, 2018–2022
2 sentences

2022Appellant claims that the prejudice he suffered should be presumed but fails to address Cronic or any other authority supporting the application of ____________________________________________ 1 United States v. Cronic, 466 U.S. 648 (1984). -6- J-S23001-22 the per se ineffectiveness analysis to the instant matter.

2018See United States v. Cronic , 466 U.S. 648 , 104 S.Ct. 2039 , 80 L.Ed.2d 657 (1984).

12
Commonwealth v. Hudsongreen
pa · 1984 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015Where, as in the instant case, the claim is counsel’s failure to file a direct appeal, Pennsylvania utilizes a per se ineffectiveness test, Commonwealth v. Lantzy, 736 A.2d 564, 571 (Pa. 1999) (“a failure to file or perfect [a direct] appeal results in a denial so fundamental as to constitute prejudice per se”), so long as an appellant establishes that he “requested [counsel to file] an appeal and that counsel disregarded the request.” Commonwealth v. Hudson, 485 A.2d 487, 489 (Pa. Super. 1984).

11
United States v. Mitchell, Dennis L.green
cadc · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2012–2012
1 sentence

2012See, e.g., U.S. v. Mitchell, 216 F.3d 1126, 1132 (D.C.Cir.2000) (“We decline appellant’s invitation to extend the per se ineffectiveness rule be yond those cases in which a defendant is represented by a person never properly admitted to any bar.”) (emphasis added); Cole v. U.S., 162 F.3d 957, 958 (7th Cir.1998) (“Only where the attorney had never been admitted to practice before any court at all, and thus should be considered a non-lawyer, have courts found per se violations of the right to counsel.”) (citation omitted and emphasis added).

11
Parrish Cole v. United Statesgreen
ca7 · 1998 · cited in 1 Pennsylvania opinions naming this issue, 2012–2012
1 sentence

2012See, e.g., U.S. v. Mitchell, 216 F.3d 1126, 1132 (D.C.Cir.2000) (“We decline appellant’s invitation to extend the per se ineffectiveness rule be yond those cases in which a defendant is represented by a person never properly admitted to any bar.”) (emphasis added); Cole v. U.S., 162 F.3d 957, 958 (7th Cir.1998) (“Only where the attorney had never been admitted to practice before any court at all, and thus should be considered a non-lawyer, have courts found per se violations of the right to counsel.”) (citation omitted and emphasis added).

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 (2)

CaseCitedYears
Commonwealth v. Postie green
pasuperct · 2018
1 sentence

2019We “decline[d] to adopt a per se ineffectiveness standard for a violation of Rule 646(C)” because “Pennsylvania law does not support that precedent.” Id. at 1029 .

12019–2019
Commonwealth v. Liebel green
pa · 2003
2 sentences

2014However, I respectfully dissent because I would conclude that Appellant properly pleaded a per se ineffectiveness claim under Commonwealth v. Liebel, 573 Pa. 375 , 825 A.2d 630 (2003).

2014However, I respectfully dissent because I would conclude that Appellant properly pleaded a per se ineffectiveness claim under Commonwealth v. Liebel, 573 Pa. 375 , 825 A.2d 630 (2003).

12014–2014

Where else courts name it

PA 7 (2012–2022) MS 2 (2014–2014)

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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