applied the Strickland test by looking to the following three elements that must be satisfied: (1) the underlying claim has arguable merit; (2) counsel had no reasonable basis for his actions or failure to act; and (3) the PCRA petitioner suffered prejudice as a result of counsel’s error, with prejudice measured by whether there is a reasonable probability that the result of the proceeding would have been different. Commonwealth v. Pierce, 515 Pa. 153, 527 A.2d 973, 975 (1987). Counsel is presumed to have rendered effective assistance of counsel. ue is laced with misrepresentations as it omits any discussion of his vicious attack on his own counsel, which precipitated counsel’s withdrawal. It submits that Appellant also ignores the PCRA court’s findings that he assert (3d Cir.1998) (<HOLDING>). It was appropriate for the PCRA court to rale
holding that a defendants unprovoked physical battery of his attorney in the courtroom constituted extremely serious misconduct that amounts to the forfeiture of the right to counsel regardless of whether the defendant intended to relinquish the right holding that the forfeiture of the right to counsel unlike the waiver of such right does not require that the defendant intend to relinquish a right but rather may be the result of the defendants extremely serious misconduct or extremely dilatory conduct holding that a defendant who stipulated his drug amounts prior to sentencing waived his right to appeal on the issue of the drug amounts holding that a defendants unprovoked physical battery of his attorney at a hearing qualifies as the sort of extremely serious misconduct that amounts to the forfeiture of the right to counsel recognizing that a criminal defendants right to counsel is the right to the effective assistance of counsel