Pennsylvania v. Pruitt

In a capital post-conviction appeal, Appellant Michael Pruitt raised six challenges, several of which fell within the category of the claims deemed to have been abandoned by the PCRA court. In 2003, Appellant forcibly entered the home of Greta Gougler, where he robbed, raped, and murdered her. Appellant was arrested, tried, and convicted for first -degree murder, rape, robbery, and other offenses, and a jury returned a death verdict in a capital sentencing proceeding. On direct appeal, the Pennsylvania Supreme Court affirmed. In 2009, Appellant brought these proceedings under the Post Conviction Relief Act (the "PCRA"). The post -conviction court conducted a series of evidentiary hearings, throughout which Appellant was represented by the members of the Federal Community Defender Office. Later, per Appellant's request, those attorneys were removed from the representation and new counsel was appointed in their place. In 2015, Appellant submitted a request to proceed pro se. The PCRA court scheduled a proceeding, at which Appellant agreed to continue to be represented by counsel but was deemed by the court to have "knowingly, intelligently and voluntarily abandon[ed] any issues raised by prior PCRA counsel and/or [current counsel] that are not contained in [a] memorandum in support of the PCRA relief petition filed this date[.]" The PCRA court subsequently denied relief on the remaining claims for relief. This appeal followed. The Supreme Court concluded the record supported the PCRA court's determination that Appellant abandoned the six claims at issue here, and affirmed the court's subsequent order. View "Pennsylvania v. Pruitt" on Justia Law