Pennsylvania v. Parrish (majority)Annotate this Case
Appellant Michael Parrish appealed a Monroe County Court of Common Pleas order denying his petition for relief pursuant to the Post Conviction Relief Act (“PCRA”). Appellant was sentenced to death for the 2009 double murder of his girlfriend, Victoria Adams and their 19-month-old son, Sidney Parrish. Following the Pennsylvania Supreme Court's request for supplemental briefing, and after careful review, the Supreme Court held that Appellant’s Statement of Matters Complained of on Appeal filed pursuant to Pa.R.A.P. 1925(b) was so vague as to render all of his claims waived for purposes of this appeal. Additionally, the Court held that appellate counsel’s filing of a "woefully deficient statement, one which precludes merits review of all appellate issues," constituted ineffective assistance of counsel per se, warranting reinstatement of Appellant’s right to file a Rule 1925(b) statement nunc pro tunc. Accordingly, the Supreme Court remanded to the PCRA court for further proceedings.