592 Pa. 222 - Commonwealth v. Crawley

How this case has been cited

Cited by 48 later decisions — most recently January 2025 · most notably Commonwealth v. Keaton (2012), Commonwealth v. Martin (2010)

2 federal appellate · 45 state decisions

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

Justice EAKIN,

¶1concurring.

¶2I join the majority opinion. I write separately to reiterate my concerns expressed in Commonwealth v. Miller, 585 Pa. 144, 888 A.2d 624, 633 (2005) (Eakin, J., concurring) (stating “no legislation has been passed to [set mental retardation standards for capital defendants since Atkins v. Virginia, 536 U.S. 304, 122 S.Ct. 2242, 153 L.Ed.2d 335 (2002), and] this is inherently a legislative matter — it is hoped that the legislature would also act without further delay.”). It has been almost five years since Atkinswas decided, and the legislature has still not acted in this regard. In the continued absence of legislative action, I agree with the three-part construct Justice Castille set forth in his concurring opinion. See Concurring Op., at 231-32, 924 A.2d at 617.