Commonwealth v. Michael Burton 2009 PA Super 87 (5/13/2009)
Topic: Statement Pursuant to 1925(b) – Waiver – Late Filing
Summary: The late filing of a 1925(b) statement is per se ineffectiveness. Therefore, the late filing of a 1925(b) statement will be treated the same as the failure to file a 1925(b) statement (The Court will not find waiver and will review the case on its merits).
