Commonwealth v. Castillo

In Commonwealth v. Castillo, 585 Pa. 395, 888 A.2d 775 (2005), the Supreme Court reiterated that the Lord/Butler rule remained necessary. It wrote: Thus, the Lord/Butler rule remains necessary to insure trial judges in each appealed case the opportunity to opine upon the issues which the appellant intends to raise, and thus provide appellate courts with records amendable to meaningful appellate review. This firm rule avoids the situation that existed prior to Lord where trial courts were forced to anticipate which issues the appellant might raise and appellate courts had to determine "whether they could conduct a 'meaningful review' despite an appellant's failure to file a Pa. R.A.P. 1925(b) statement or to include certain issues within a filed statement." Moreover, the system provides litigants with clear rules regarding what is necessary for compliance and certainty of result for failure to comply. Castillo, 585 Pa. at 402, 888 A.2d at 779-80.