context: I disagree with the conclusion of the Majority that these ineffectiveness claims are waived. See Majority Op. at p. 328. After much reflection upon, and study of, our precedent in this area, I believe that Appellant, through tag lines and boilerplate language, has sufficiently presented all of these claims for our review, despite framing some as trial court error, constitutional violations, prosecutorial misconduct, and trial counsel ineffectiveness.
citation_a.signal: but see
citation_a.identifier: 795 A.2d 935, 939-40
citation_a.parenthetical: claims of trial court error, constitutional error, and prosecuto-rial misconduct are waived despite being accompanied by tag line asserting ineffectiveness of prior counsel for failing to raise such claims
citation_a.sentence: See Commonwealth v. Hawkins, 567 Pa. 310, 787 A.2d 292 (2001) (reviewing merits of claims of ineffectiveness of PCRA counsel for failing to raise prior counsel’s ineffectiveness); Commonwealth v. Williams, 566 Pa. 553, 782 A.2d 517, 525 (2001) (“a majority of this Court would presently continue to allow a degree of latitude” in developing layered ineffective assistance of counsel claims in briefs); Commonwealth v. Miller, 560 Pa. 500, 746 A.2d 592, 598 n. 3 (2000) (noting that “these ineffectiveness claims are properly layered because appellant argues that all of his prior counsel were ineffective for failing to assert the claims of trial court error”); Commonwealth v. Marrero, 561 Pa. 100, 748 A.2d 202, 204 n. 1 (2000) (claims of trial counsel ineffectiveness accompanied by claims of appellate counsel ineffectiveness for failing to raise trial counsel ineffectiveness claims are “properly layered”); but see Commonwealth v. Bracey, 568 Pa. 264, 795 A.2d 935, 939-40 (2001) (claims of trial court error, constitutional error, and prosecuto-rial misconduct are waived despite being accompanied by tag line asserting ineffectiveness of prior counsel for failing to raise such claims); Commonwealth v. Abdul-Salaam, 808 A.2d 558, 560 (Pa.2001) (same).
citation_b.signal: see
citation_b.parenthetical: reviewing merits of claims of ineffectiveness of PCRA counsel for failing to raise prior counsel's ineffectiveness
citation_b.sentence: See Commonwealth v. Hawkins, 567 Pa. 310, 787 A.2d 292 (2001) (reviewing merits of claims of ineffectiveness of PCRA counsel for failing to raise prior counsel’s ineffectiveness); Commonwealth v. Williams, 566 Pa. 553, 782 A.2d 517, 525 (2001) (“a majority of this Court would presently continue to allow a degree of latitude” in developing layered ineffective assistance of counsel claims in briefs); Commonwealth v. Miller, 560 Pa. 500, 746 A.2d 592, 598 n. 3 (2000) (noting that “these ineffectiveness claims are properly layered because appellant argues that all of his prior counsel were ineffective for failing to assert the claims of trial court error”); Commonwealth v. Marrero, 561 Pa. 100, 748 A.2d 202, 204 n. 1 (2000) (claims of trial counsel ineffectiveness accompanied by claims of appellate counsel ineffectiveness for failing to raise trial counsel ineffectiveness claims are “properly layered”); but see Commonwealth v. Bracey, 568 Pa. 264, 795 A.2d 935, 939-40 (2001) (claims of trial court error, constitutional error, and prosecuto-rial misconduct are waived despite being accompanied by tag line asserting ineffectiveness of prior counsel for failing to raise such claims); Commonwealth v. Abdul-Salaam, 808 A.2d 558, 560 (Pa.2001) (same).