Commonwealth v. Marvin Jamine Robinson 2009 PA Super 65 (4/09/2009)
Topic: Post-Conviction Relief Act – Pro se Representation
Summary: Where an appellant wishes to represent himself in a PCRA proceeding, the court must conduct a full colloquy pursuant to Pa.R.Crim.P. 121 before permitting the appellant to proceed pro se.
Note: This decision overrules the opinion in Commonwealth v. Murray, 836 A.2d 956 (Pa.Super. 2003) concluding that a hearing is not required when an appellant wishes to represent himself in a PCRA proceeding.