Right to Counsel • Waiver • Magisterial District Court • Trial Court • Suppression Hearing
Commonwealth v. Johnson, PICS Case No. 17-0455(Pa. Super. March 21, 2017) Stabile, J. (11 pages).
Trial court erred in not determining on the record whether appellant knowingly, voluntarily and intelligently waived his right to counsel before holding a suppression hearing because appellant’s waiver of his right to counsel at the magisterial district court was limited to matters before the district court and was insufficient at subsequent events before the trial court. Vacated.
