Justices press whether lower court improperly treated PCRA motion as summary judgment

Mar 16, 2026

Bench questioned whether the district court converted a Rule 12(b)(6) motion into a summary-judgment-style ruling by relying on materials outside the petition; appellant argued the conversion (if it occurred) required notice or remand.

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A recurring procedural issue at argument was whether the district court applied a Rule 12(b)(6) standard or treated the case as if on summary judgment by considering materials outside the petition.

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