Task: Text Completion
Input (English): him his constitutional right to counsel by permitting counsel to withdraw and by adjudicating the claims presented in his pro se PCRA petition. He cites testimony from a previous hearing conducted on August 30, 2012, during which Appellant expressed his desire for counsel and the PCRA court categorized some of his pro se arguments as “unintelligible.” N.T., Aug. 30, 2012, at 11. According to Appellant, if his pro se petition was unintelligible, the court had a constitutional duty in this capital case to appoint qualified counsel so that the issues could be identified more clearly, rather than proceed to address and reject them as presented, resulting in a complete denial of counsel. See Brief for Appellant at 17-18 (citing Commonwealth v. Padilla, 622 Pa. 449, 80 A.3d 1238, 1253 (2013) (<HOLDING>); and Commonwealth v. Albrecht, 554 Pa. 31, 720 
 Holding statements: (A) holding that sentencing is a critical stage of criminal proceedings and the offer of counsel must be renewed at each critical stage where the defendant appears without counsel (B) recognizing that the sixth amendment guarantees a defendant the right to counsel and the right to waive counsel (C) holding that a criminal defendant has a sixth amendment right to counsel at trial (D) holding that the filing of a motion for a new trial is a critical stage of the prosecution and that an indigent defendant is constitutionally entitled to the assistance of counsel at that stage (E) holding that a conviction will generally be vacated for a violation of the sixth amendment right to counsel only where the reliability of the trial has been undermined but prejudice is presumed where the defendant suffers a complete denial of counsel during a critical stage of trial
Output (English): (E)