quality of his own defense (Pennsylvania) · Go Syfert
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quality of his own defense in Pennsylvania

6 Pennsylvania opinions name it 3 courts 2004–2025 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 (5)

CaseFollowedCited
Faretta v. Californiagreen
scotus · 1975 · cited in 6 Pennsylvania opinions naming this issue, 2004–2025
2 sentences

2025See Faretta, 422 U.S. at 834 n.46 (“[W]hatever else may or may not be open to him on appeal, a defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of ‘effective assistance of counsel.’”). -4- J-A17034-25 presenting evidence “to defend against” the Commonwealth’s case, id., yet he does not discuss what specific evidence the court precluded.

2025See Faretta, 422 U.S. at 834 n.46 (“[W]hatever else may or may not be open to him on appeal, a defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of ‘effective assistance of counsel.’”). -4- J-A17034-25 presenting evidence “to defend against” the Commonwealth’s case, id., yet he does not discuss what specific evidence the court precluded.

46
Commonwealth v. Bryantgreen
pa · 2004 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
2 sentences

2008Indeed, “[a] criminal defendant who knowingly and intelligently waives his right to counsel so that he may represent himself at trial may not later rely upon his own lack of legal expertise as a ground for a new trial.” Commonwealth v. Bryant, 579 Pa. 119, 136 , 855 A.2d 726, 736 (2004) (citing Faretta, 422 U.S. at 834 n.46 (“[A] defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of effective assistance of counsel.”)); see also, Appel, 547 Pa. at 198 , 689 A.2d at 904 (“claims of inef fective assistance of counsel are n

2008Indeed, “[a] criminal defendant who knowingly and intelligently waives his right to counsel so that he may represent himself at trial may not later rely upon his own lack of legal expertise as a ground for a new trial.” Commonwealth v. Bryant, 579 Pa. 119, 136 , 855 A.2d 726, 736 (2004) (citing Faretta, 422 U.S. at 834 n.46 (“[A] defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of effective assistance of counsel.”)); see also, Appel, 547 Pa. at 198 , 689 A.2d at 904 (“claims of inef fective assistance of counsel are n

11
Commonwealth v. Appelgreen
pa · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
2 sentences

2008Indeed, “[a] criminal defendant who knowingly and intelligently waives his right to counsel so that he may represent himself at trial may not later rely upon his own lack of legal expertise as a ground for a new trial.” Commonwealth v. Bryant, 579 Pa. 119, 136 , 855 A.2d 726, 736 (2004) (citing Faretta, 422 U.S. at 834 n.46 (“[A] defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of effective assistance of counsel.”)); see also, Appel, 547 Pa. at 198 , 689 A.2d at 904 (“claims of inef fective assistance of counsel are n

2008Indeed, “[a] criminal defendant who knowingly and intelligently waives his right to counsel so that he may represent himself at trial may not later rely upon his own lack of legal expertise as a ground for a new trial.” Commonwealth v. Bryant, 579 Pa. 119, 136 , 855 A.2d 726, 736 (2004) (citing Faretta, 422 U.S. at 834 n.46 (“[A] defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of effective assistance of counsel.”)); see also, Appel, 547 Pa. at 198 , 689 A.2d at 904 (“claims of inef fective assistance of counsel are n

11
Commonwealth v. Szuchongreen
pa · 1984 · cited in 1 Pennsylvania opinions naming this issue, 2004–2004
2 sentences

2004See Faretta v. California, 422 U.S. 806 , 834 n. 46, 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975) ("[A] defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of `effective assistance of counsel.'"); Commonwealth v. Griffin, 537 Pa. 447 , 644 A.2d 1167, 1171 (1994); Commonwealth v. Szuchon, 506 Pa. 228 , 484 A.2d 1365, 1377 (1984) ("To hold otherwise would create a situation wherein a defendant, by design, could build into his case ineffective assistance of counsel claims, thus guaranteeing himself a basis for a new trial if the v

2004See Faretta v. California, 422 U.S. 806 , 834 n. 46, 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975) ("[A] defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of `effective assistance of counsel.'"); Commonwealth v. Griffin, 537 Pa. 447 , 644 A.2d 1167, 1171 (1994); Commonwealth v. Szuchon, 506 Pa. 228 , 484 A.2d 1365, 1377 (1984) ("To hold otherwise would create a situation wherein a defendant, by design, could build into his case ineffective assistance of counsel claims, thus guaranteeing himself a basis for a new trial if the v

11
Commonwealth v. Griffingreen
pa · 1994 · cited in 1 Pennsylvania opinions naming this issue, 2004–2004
2 sentences

2004See Faretta v. California, 422 U.S. 806 , 834 n. 46, 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975) ("[A] defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of `effective assistance of counsel.'"); Commonwealth v. Griffin, 537 Pa. 447 , 644 A.2d 1167, 1171 (1994); Commonwealth v. Szuchon, 506 Pa. 228 , 484 A.2d 1365, 1377 (1984) ("To hold otherwise would create a situation wherein a defendant, by design, could build into his case ineffective assistance of counsel claims, thus guaranteeing himself a basis for a new trial if the v

2004See Faretta v. California, 422 U.S. 806 , 834 n. 46, 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975) ("[A] defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of `effective assistance of counsel.'"); Commonwealth v. Griffin, 537 Pa. 447 , 644 A.2d 1167, 1171 (1994); Commonwealth v. Szuchon, 506 Pa. 228 , 484 A.2d 1365, 1377 (1984) ("To hold otherwise would create a situation wherein a defendant, by design, could build into his case ineffective assistance of counsel claims, thus guaranteeing himself a basis for a new trial if the v

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Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 9543 (4) PA § 42 Pa. Cons. Stat. § 9544 (4)

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

CA 14 (1976–2023) OH 13 (2002–2026) MO 10 (1979–2021) TX 10 (1976–2022) MI 7 (2015–2025) UT 7 (1977–2021) TN 6 (1997–2023) IA 6 (1991–2016) PA 6 (2004–2025) FL 5 (1984–2008) ND 5 (1997–2016) MS 5 (2009–2019) NC 4 (1979–2012) CO 3 (1980–2023) MN 3 (1990–2011) KY 3 (2009–2022) LA 3 (1986–1994) AR 3 (2005–2022) WI 3 (2018–2024) IN 3 (2017–2018) NJ 2 (2004–2023) WA 2 (2006–2006) KS 2 (2013–2020) AL 2 (1988–1988) IL 2 (1984–2024) NH 2 (1981–2019) HI 2 (1994–2009)

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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