Filing a Pro Se Brief Before After Your Lawyer Already Filed An Appellate Brief

In Commonwealth v. Ellis, 534 Pa. 176, 626 A.2d 1137 (1993), the criminal defendant attempted to file a pro se brief before the Court after his counsel filed an appellate brief. Terming this "hybrid representation," the Court held the defendant enjoyed "no constitutional right to hybrid representation either at trial or on appeal." Ellis, 534 Pa. at 180, 626 A.2d at 1139. Moreover, the Court addressed the policy considerations for allowing such an appeal and found the defendant "may not . . . confuse and overburden the court by his own pro se filings of briefs at the same time his counsel is filing briefs on his behalf." Id. at 184, 626 A.2d at 1141.