Commonwealth v. Champney, 65 A.3d 386

Champney challenged a PCRA order granting him a new trial based on five ineffective-assistance claims against trial counsel.
The five claims center on suppression issues and impeachment strategies related to statements Champney made to police in 1997–1998 after invoking a right to counsel, and on impeachment and evidentiary strategies at trial.
Key suppression issue: May 13, 1998 statement obtained after Champney invoked counsel; PCRA court found merit and counsel deficient for not moving to suppress.
Key suppression issue: October 8, 1998 statement was unsolicited; PCRA court found suppression warranted but the majority later disagreed on its preclusion effect.
Additional issues: failure to obtain/parade Blickley impeachment material (parole records, police report), failure to hire a forensic expert, and a prosecutor's comment on Champney’s silence.
Financial and procedural posture: the Court split, with one branch asserting relief, another reversing on specific issues and remanding for cumulative prejudice analysis on impeachment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May 13, 1998 suppression	Champney argues counsel was ineffective for not seeking suppression after invoking counsel.	Commonwealth contends invocation was not unequivocal; suppression not warranted.	Trial counsel ineffective; new trial affirmed.
October 8, 1998 suppression	Champney claims this unsolicited statement should have been suppressed under Edwards/Miranda.	Commonwealth argues it was not compelled by invocation and not suppressible.	PCRA erred; treatment of October 8 statement reversed; not suppressed.
Brady/impeachment of Blickley using parole records	Parole records would impeach Blickley and were Brady material.	Records were accessible; no Brady violation; impeachment strategy not properly pursued.	No Brady violation; three other impeachment issues addressed on remand.
Impeachment with police report on Blickley	Police report showing Blickley omitted Champney’s confessions would impeach credibility.	Omission alone not prejudicial; cumulative prejudice considered later.	Arguable merit; not prejudicial alone; remand for cumulative prejudice analysis.
Prosecutor's reference to Champney's silence	Counsel was ineffective for not objecting to improper comment on post-arrest silence.	Statement did not amount to improper comment on silence; permissible in context.	PCRA erred; prosecutor’s silence reference not grounds for ineffective assistance; reversed.

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (established right to counsel during custodial interrogation)
Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (once invoked, interrogation must cease until counsel present)
Davis v. United States, 512 U.S. 452 (U.S. 1994) (unambiguous invocation required for cessation unless clarified)
McNeil v. Wisconsin, 501 U.S. 171 (U.S. 1991) (requires clear expression of desire for attorney)
Arizona v. Roberson, 486 U.S. 675 (U.S. 1988) (reinterrogation regardless of offense if right to counsel invoked)
Maryland v. Shatzer, 559 U.S. 98 (U.S. 2010) (break in custody can terminate Edwards protections after certain period)
Howes v. Fields, 132 S. Ct. 1181 (U.S. 2012) (clarifies custody/in custody distinctions for interrogation after imprisonment)
Berghuis v. Thompkins, 560 U.S. 370 (U.S. 2010) (unambiguous invocation required; silence not invoked if not explicit)
Commonwealth v. Jermyn, 533 A.2d 74 (Pa. 1987) (volunteered or evasive responses not protected by Fifth Amendment)