Public Defender's Office v. Venango County Court of Common Pleas

OPINION

Justice BAER.

At issue is whether the Venango County Court of Common Pleas may order a public defender acting in his official capacity (as opposed to having been privately appointed with compensation additional to his public defender salary) to serve as standby counsel for a pro se criminal defendant, who previously had been denied public defender representation because his annual income exceeded the financial guidelines established by the Venango County Public Defender’s office (herein, “the Public Defender’s Office”). For the reasons that follow, we hold that within the circumstances…