serving a short sentence. To the extent Martinez may afford defendants review in federal court of claims which the state court has not reviewed, such a possibility does not extend to short sentence defendants who, like Petitioner, would not be able to satisfy the custody requirement of the federal ha-beas statute by being subject to a sentence at the time the federal habeas petition is filed. See Maleng, 490 U.S. at 490-91, 109 S.Ct. 1923 (observing that the Court has interpreted the federal habeas corpus custody requirement as being satisfie ideration nor raised her claim earlier to afford more time for review. Consequently, the PCRA did not bar her opportunity to be heard as she asserts and as the PCRA court found. See Commonwealth v. Fahy, 558 Pa. 313, 737 A.2d 214, 220 (1999) (<HOLDING>). Because it is Petitioner’s burden to prove
holding that the denial of pcra relief cannot stand unless the petitioner was afforded the assistance of counsel holding that the constitutional nature of the violations alleged in a pcra petition has no effect on the application of the pcra jurisdictional time bar holding that where the appellant had the opportunity to bring his petition within the parameters of the jurisdictional requirements of the pcra yet did not do so he cannot complain of a lack of due process holding that because an untimely pcra petition was premised on claims that were cognizable under the pcra the statutory writ of habeas corpus was unavailable holding that a pcra petitioner may not raise new claims by merely supplementing a pending pcra petition without court authorization because to do so would wrongly subvert the time limitation and serial petition restrictions of the pcra