Commonwealth of Pennsylvania v. Justin David Holmes

Summary

The Supreme Court of Pennsylvania reaffirmed Grant's general rule deferring ineffective-assistance-of-counsel claims to PCRA collateral review, disapproved expansions of the Bomar exception, and limited Bomar to its pre-Grant, Hubbard-era facts. It recognized two discretionary exceptions: trial courts may entertain discrete, record-based, apparently meritorious ineffectiveness claims under extraordinary circumstances, and may conduct unitary review of prolix or non-record-based claims only upon good cause and the defendant's knowing, express waiver of PCRA review subject to the Section 9545(b) time-bar and serial-petition restrictions. Because Holmes's claims arose in a post-Grant PCRA posture outside Bomar, the Court vacated the Superior Court's order remanding for nunc pro tunc post-sentence motions and remanded to the trial court, also concluding that Martinez and Trevino do not require a different result. Justice Baer joined the majority while explaining his changed position; Justices Saylor, Eakin (joined by McCaffery), and Todd (joined by McCaffery) concurred, with Todd and Eakin objecting to the breadth of the required PCRA waiver and Saylor urging guaranteed review in short-sentence cases.