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593 Pa. 382

930 A.2d 1264

Commonwealth v. Bennett

Supreme Court of Pennsylvania

Decided August 23, 2007

Supreme Court of Pennsylvania · decided 2007-08-23

Key passage — most relied on by later courts

“(b) Time for filing petition.- (1) Any petition under this subchapter, including a second or subsequent petition, shall be filed within one year of the date the judgment becomes final, unless the petition alleges and the petitioner proves that: (i) the failure to raise the claim previously was the result of interference by government officials with the presentation of the claim in violation of the Constitution or laws of this Commonwealth or the Constitution or laws of the United States; (ii) the facts upon which the claim is predicated were unknown to the petitioner and could not have been ascertained by the exercise of due diligence; or (iii) the right asserted is a constitutional right that was recognized by the Supreme Court of the United States or the Supreme Court of Pennsylvania after the time period provided in this section and has been held by that court to apply retroactively.”

quoted by 20 later decisions, including Commonwealth v. Smith, Commonwealth v. Hill

Relies on Commonwealth v. Peterkin · Commonwealth v. Lark · Commonwealth v. Yarris

Good law ✅— No negative treatment on recordhow we know

Decided 2007-08-23

How this case has been cited

Cited by 176 later decisions — most recently February 2026 · most notably Commonwealth v. Burton (2015), Commonwealth v. Lesko (2011)

4 federal appellate · 168 state decisions

1320200720102020decided

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.

View the full empirical analysis of this case →

Justice EAKIN,

¶1Dissenting.

¶2I dissent because I believe Commonwealth v. Chester, 586 Pa. 468, 895 A.2d 520 (2006) controls this matter.

¶3Under the Post Conviction Relief Act (PCRA), 42 Pa.C.S. § 9541 et seq., all petitions, including second or subsequent petitions, must be filed within one year of the date the judgment of sentence becomes final, unless one of the statutory exceptions applies. Chester, at 522 (citing 42 Pa.C.S. § 9545(b)(1); Commonwealth v. Yarris, 557 Pa. 12, 731 A.2d 581 (1999)). The PCRA’s time-bar is jurisdictional in nature. Commonwealth v. Peterkin, 554 Pa. 547, 722 A.2d 638, 641 (1998). Appellant argues this Court should consider his PCRA petition under the exception to the one-year time limitation in 42 Pa.C.S. § 9545(b)(1)(ii). This subsection requires a petitioner to prove the facts upon which the claim is predicated were unknown to him and could not have been ascertained by the exercise of due diligence. Chesterrecognized “for purposes of 42 Pa.C.S. § 9545(b)(1)(ii), information is not ‘unknown’ to a PCRA petitioner when the information was a matter of public record.” Chester, at 523 (citing Commonwealth v. Lark, 560 Pa. 487, 746 A.2d 585, 588 n. 4 (2000); Commonwealth v. Whitney, 572 Pa. 468, 817 A.2d 473, 478 (2003)). Under Chester, it is clear information that is a matter of public record — like the dismissal of an appeal — is not “unknown” to a PCRA petitioner. Therefore, appellant cannot meet § 9545(b)(1)(ii).

¶4Because the time-bar is jurisdictional, and this PCRA petition is clearly time-barred, I respectfully dissent.

Justice CASTILLE joins this dissenting opinion.
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