Pennsylvania v. Mason (majority)
Annotate this CaseAppellant Lenwood Mason's convictions arose from the June 1994, stabbing death of Iona Jeffries, for which he received the death penalty. His first Post-Conviction Relief Act petition was dismissed, and he appealed. Appellant contended that the cumulative effect of errors committed by the trial court and trial counsel’s ineffectiveness prevented the jury from hearing important evidence relevant to making its guilt phase and sentencing determinations. He raised eleven claims of error on appeal to the Supreme Court. With respect to issues one through six, and eight through eleven, the Supreme Court affirmed the PCRA court. In issue seven, Appellant's PCRA petition was pending when the U.S. Supreme Court decided "Atkins v. Virginia," (536 U.S. 304 (2002)). With respect to issue seven, Appellant argued that under Atkins, he was ineligible for the death penalty, and that the PCRA court erred in permitting Appellant acting pro se (over trial counsel's objection), to "waive" this claim. The Supreme Court found that, "where confronted with neither a basic, fundamental decision concerning Appellant’s PCRA challenge nor disagreement between counsel and Appellant with respect to the overarching objectives of the challenge, the PCRA court erred in ruling that counsels’ authority to seek an Atkins hearing was subject to Appellant’s veto. Furthermore, by acting directly on Appellant’s pro se letter moving for the court to accept his waiver of the counseled Atkins claim, the PCRA court impermissibly invited hybridized representation." The Supreme Court reversed on issue seven and remanded this case for further proceedings.
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