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6 Pennsylvania opinions name it 1 courts 2017–2025 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. Holmesgreen2 sentences2024Holmes, 79 A.3d at 577-78 (emphases added). 2024Holmes, 79 A.3d at 577-78 (emphases added). | 3 | 4 |
Commonwealth v. Brittgreen1 sentence2022See Holmes, 79 A.3d at 564 ; see also Commonwealth v. Britt, 83 A.3d 198, 204 (Pa. Super. 2013) (declining to address ineffectiveness claims on direct appeal where the facts did not invoke the Holmes exceptions, and the appellant did not waive his rights to PCRA review). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Com. v. Watson, F.
green
2 sentences2025With respect to the second Holmes exception, we held that Appellant neither argued he had good cause for raising ineffective assistance claims in a post sentence motion, nor made “a knowing waiver of his right to [subsequent] PCRA review.” Id. at 312 . 2025Additionally, the trial court did not make a finding that there was good cause. -7- J-S15039-25 Id. | 1 | 2025–2025 |
McMullen v. Com. of Pa.
green
1 sentence2020Id. | 1 | 2020–2020 |