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← 408 Pa. Super. 68 - Commonwealth v. Hayes

408 Pa. Super. 68 - Commonwealth v. Hayes’s Empirical Analysis

1991

Citation profile

16
cited by 16 later decisions
1
states following
December 2016
most recently cited

2 federal appellate · 14 state decisions

Relationships

Applies 28 U.S.C. § 2255 (Antiterrorism and Effective Death Penalty Act of 1996)

Relies on Sibron v. State of New York Peters · United State v. Morgan · Carafas v. J · Maleng v. Cook · Street v. New York

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Since the legislature rewrote the eligibility requirements, our examination of the specific language, in particular the inclusion of the adverb “currently,” leads to the conclusion that the legislature intended to limit post-conviction relief under the PCRA to individuals who at the time of filing for PCRA relief are serving a sentence of imprisonment, probation or parole for a conviction, regardless of the collateral criminal consequences from the conviction.... We conclude that the language changes in the PCRA were deliberately made to confront and alter the collateral criminal consequences rule. Therefore we decline to interject the collateral criminal consequences rule into the PCRA. To do so ignores the legislature’s intent and the plain meaning of the word changes made in the PCRA. In summary, we find that the legislature has clearly modified the eligibility requirements under the PCRA from those that previously existed under the PCHA.... [W]e find the enactment of the PCRA precludes post-conviction relief under the PCRA where the petitioner’s sentence of imprisonment, probation or parole has expired prior to filing for relief....”
    2 later decisions quote this exact passage
  2. “The Post Conviction Relief Act, when read as a whole and in conjunction with its predecessor, the Post Conviction Hearing Act and the law pertaining to federal habeas corpus relief, leads us to conclude that the language of the Post Conviction Relief Act pertaining to eligibility for relief was intended to limit relief to those petitioners whose sentences have not expired and to preclude relief for those whose sentences have expired, regardless of collateral consequences.”
    1 later decision quote this exact passage
  3. “[t]he PCRA ... is a complete amendment to the prior post conviction relief statute[,] the [PCHA]. A review of the modifications and amendments to the PCHA shows that almost the entire statutory language of the PCHA was stricken and replaced by new language in the PCRA”
    1 later decision quote this exact passage

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.