Commonwealth v. Walker, 36 A.3d 1

Walker murdered one man and shot another during a home invasion; he confessed post-arrest but claimed self-defense at trial.
Jury convicted Walker of first-degree murder; penalty phase found two aggravating factors and one mitigating factor, yielding a death sentence.
Walker obtained new counsel on PCRA and sought guilt-phase relief via new trial; the PCRA court denied guilt-phase relief but granted a new penalty-phase proceeding.
The Pennsylvania Supreme Court affirmed, addressing due-process/Brady claims, numerous ineffective-assistance claims, and the issue of whether guilt-phase claims warranted an evidentiary hearing.
Issues were raised as to disclosure of the victim’s criminal history, trial and appellate counsel ineffectiveness, whether guilt-phase claims warranted a hearing, and the cumulative effect of alleged errors.
The concurrence discusses layered claims under McGill and Grant, and the dissent questions the approach to waiver and appellate counsel’s duties in post-McGill contexts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Brady materiality of victim’s criminal history	Walker contends the state withheld the victim’s criminal record, aiding self-defense theory.	Commonwealth argues the arrest record would be inadmissible and thus not prejudicial.	No prejudice; undisclosed record would not have changed guilt-phase result.
Trial counsel ineffective for failing to investigate/present evidence at guilt phase	Walker asserts counsel should have pursued evidence supporting heat of passion/self-defense.	Record showed cooling-off period; defenses not supported by evidence; strategic choices were reasonable.	Claims failing; no reasonable probability of different outcome.
Guilt-phase claims entitlement to evidentiary hearing	PCRA judge erred in denying guilt-phase relief without an evidentiary hearing.	Record establishes no genuine issue of material fact requiring a hearing.	affirmed denial of guilt-phase relief without a hearing.
Cumulative error doctrine	Cumulative effects of asserted errors warrant relief.	Aggregate claims do not establish prejudice.	Cumulative-error claim rejected.
Layered ineffectiveness and waiver post-McGill/Grant	Appellate counsel should not be faulted for relying on relaxed waiver/Griffin-era rules; issues were properly layered.	Counsel’s reliance on pre-Grant waiver doctrines was unreasonable; claims faltered on merits.	No appellate-counsel ineffectiveness; underlying trial-counsel claims fail.

Commonwealth v. Williams, 557 Pa. 207 (1999) (PCRA standard for relief and governing standards of review)
Commonwealth v. McGill, 574 Pa. 574 (2003) (framework for layered ineffective-assistance claims (post-Hubbard era))
Commonwealth v. Rush, 576 Pa. 3 (2003) (Pierce test and layering of appellate claims; prejudice required)
Commonwealth v. Hubbard, 472 Pa. 259 (1977) (waiver rule for trial-ineffectiveness claims on direct appeal)
Commonwealth v. Albrecht, 554 Pa. 31 (1998) (relaxed waiver doctrine; later limited by Grant/DeHart developments)
Commonwealth v. Grant, 572 Pa. 48 (2002) (channeling ineffectiveness claims to collateral review; limits Hubbard-era waivers)
Commonwealth v. Ly, 602 Pa. 268 (2009) (discussion of layering/relaxed waiver in post-Graham era scenarios)
Commonwealth v. DeHart, 539 Pa. 5 (1994) (earlier relaxed-waiver posture; transitional for direct-appeal claims)