realm defense (Pennsylvania) · Go Syfert
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realm defense in Pennsylvania

7 Pennsylvania opinions name it 2 courts 2001–2017 0 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 (5)

CaseFollowedCited
Commonwealth v. Gribblegreen
pa · 1997 · cited in 5 Pennsylvania opinions naming this issue, 2001–2007
2 sentences

2007See also Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (citations omitted) (relaxed waiver did not apply to appellant’s suppression claim because he withdrew pre-trial motion to suppress and, as result, Commonwealth was denied opportunity to respond and this Court was left without proper evidentiary record).

2007See also Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (citations omitted) (relaxed waiver did not apply to appellant’s suppression claim because he withdrew pre-trial motion to suppress and, as result, Commonwealth was denied opportunity to respond and this Court was left without proper evidentiary record).

55
Commonwealth v. Szuchongreen
pa · 1984 · cited in 3 Pennsylvania opinions naming this issue, 2001–2003
2 sentences

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

33
Commonwealth v. Wallacegreen
pa · 1989 · cited in 3 Pennsylvania opinions naming this issue, 2001–2003
2 sentences

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

33
Commonwealth v. Peterkingreen
pa · 1986 · cited in 2 Pennsylvania opinions naming this issue, 2001–2003
2 sentences

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

22
Commonwealth v. Abu-Jamalgreen
pa · 1989 · cited in 1 Pennsylvania opinions naming this issue, 2003–2003
2 sentences

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

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. Freeman green
pa · 2003
2 sentences

2007When faced with collateral claims that direct appeal counsel was ineffective in failing to invoke then-available relaxed waiver to secure review of a claim waived below, this Court has stressed the difficulty in determining the likelihood that the Court would have employed the discretionary doctrine: As this Court noted in Freeman, swpra, we have routinely declined to apply the discretionary relaxed waiver doctrine “in many instances, often involving situations where the failure to raise a claim below might have fallen within the realm of defense trial strategy, or when the absence of a contem

2007When faced with collateral claims that direct appeal counsel was ineffective in failing to invoke then-available relaxed waiver to secure review of a claim waived below, this Court has stressed the difficulty in determining the likelihood that the Court would have employed the discretionary doctrine: As this Court noted in Freeman, supra, we have routinely declined to apply the discretionary relaxed waiver doctrine "in many instances, often involving situations where the failure to raise a claim below might have fallen within the realm of defense trial strategy, or when the absence of a contem

22004–2007
Mead Data Central, Inc. v. West Publishing Co. green
scotus · 1987
2 sentences

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

22001–2003
LaBranche v. United States Olympic Committee green
scotus · 1987
2 sentences

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court's obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

22001–2003
Commonwealth v. Howe green
pasuperct · 2004
1 sentence

2017Commonwealth v. Howe, 842 A.2d 436 , 445- 6 This is not an exhaustive list; members of the SOAB are permitted to examine information outside of the realm of these factors where appropriate. 19 446 (Pa. Super. 2004).

12017–2017
Commonwealth v. O'Donnell green
pa · 1999
2 sentences

2004Ultimately, the O'Donnell Majority held that the principles which governed jury waivers generally should also apply in the specific realm of the waiver of a penalty phase jury. 740 A.2d at 212 .

2004Ultimately, the O’Donnell Majority held that the principles which governed jury waivers generally should also apply in the specific realm of the waiver of a penalty phase jury. 740 A.2d at 212 .

12004–2004
Simmons v. South Carolina green
scotus · 1994
2 sentences

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

12003–2003
Commonwealth v. Spotz green
pa · 2000
2 sentences

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

2003E.g., Commonwealth v. Spotz, 563 Pa. 269 , 759 A.2d 1280 , 1291 n. 14 (2000) (waived issue under Simmons v. South Carolina, 512 U.S. 154 , 114 S.Ct. 2187 , 129 L.Ed.2d 133 (1994) not subject to relaxed waiver review; trial court’s obligation to issue Simmons charge requires defense request for charge); Commonwealth v. Gribble, 550 Pa. 62 , 703 A.2d 426, 434-35 (1997) (suppression issue waived where defendant withdrew pre-trial motion to suppress, thereby depriving Commonwealth of opportunity to meet burden of proving that evidence was lawfully seized); Commonwealth v. Wallace, 522 Pa. 297 , 56

12003–2003

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 9541 (6) PA § 42 Pa. Cons. Stat. § 9711 (6) PA § 42 Pa. Cons. Stat. § 9543 (4) PA § 18 Pa. Cons. Stat. § 2502 (3) PA § 42 Pa. Cons. Stat. § 9544 (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

IL 8 (1924–2014) PA 7 (2001–2017) FL 6 (1985–2008) NJ 2 (2005–2005) WA 2 (2024–2024)

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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