brought that case within the Hubbard rule, rather than the Grant rule of deferral, and therefore required a remand to address the claims of ineffectiveness raised when new counsel entered an appearance. O’Berg, 880 A.2d at 606-07 (Saylor, J., dissenting). Justice Saylor’s dissenting opinion also suggested that because PCRA review is unavailable to defendants serving short sentences, due process concerns of fundamental fairness are answered by allowing short-sentence defendants to raise ineffectiveness claims on direct appeal. Id. at 606. 7 . Notably, in addition to reviewing this Court's consideration of the Bomar exception in post-Grant cases, our recent decision in Holmes generally limited Bomar to its pre-Grant facts and reaffirmed the rationale of Grant. See Holmes, 79 A.3d at 576 (<HOLDING>). Notwithstanding this general rule, we created
holding ineffective assistance of counsel claims may be decided on direct appeal where the district court has developed a record on the ineffectiveness issue holding that ineffective assistance of counsel claims should be brought in collateral proceedings not on direct appeal holding that claims of ineffective assistance of counsel are to be deferred to pcra review trial courts should not entertain claims of ineffectiveness upon postverdict motions and such claims should not be reviewed upon direct appeal holding that review of counsel ineffectiveness claims should be deferred until collateral review holding that a petitioner should wait to raise claims of ineffective assistance of trial counsel until collateral review