Justia Pennsylvania Supreme Court Opinion Summaries

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Pertinent to this appeal, the Motor Vehicle Financial Responsibility Law (“MVFRL”) required insurers to offer insureds Underinsured Motorist coverage. Subsection 1731(c.1) of the MVFRL stated that any UIM coverage rejection form that does not “specifically comply” with Section 1731 of the MVFRL was void and that, if an insurer failed to produce a valid UIM coverage rejection form, then UIM coverage shall be equal to the policy’s bodily injury liability limits. The Pennsylvania Supreme Court granted allowance of appeal in this matter to determine whether an insurer’s UIM coverage rejection form “specifically compl[ied]” with Section 1731 of the MVFRL if the insurer’s form was not a verbatim reproduction of the statutory rejection form found in Subsection 1731(c) of the MVFRL but, rather, differed from the statutory form in an inconsequential manner. The Court held that a UIM coverage rejection form specifically complies with Section 1731 of the MVFRL even if the form contains de minimis deviations from the statutory form. Because the Superior Court reached the proper result in this case, the Supreme Court affirmed that court’s judgment. View "Ford v. American States Ins." on Justia Law

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In this case, two townships disputed the location of their common boundary. Pursuant to the Second Class Township Code, the trial court appointed three commissioners to ascertain that boundary. The Pennsylvania Supreme Court granted allowance of appeal to consider whether such commissioners, when tasked with determining the location of a municipal boundary but concluding that they could not do so with certainty, could consider the townships’ acquiescence to a line used as the boundary and relied upon by residents, and accordingly recommend the adoption of that alternative line as the municipal boundary. The Supreme Court concluded that, in such a narrow circumstance, the commissioners could rely upon the equitable doctrine of acquiescence in making their determination, and need not search indefinitely for evidence of the original boundary. Accordingly, the Court reversed the order of the Commonwealth Court and remanded for reinstatement of the trial court’s order. View "Adams Twp. v. Richland" on Justia Law

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Appellant Bernard Cousar appealed a Court of Common Pleas order denying, without a hearing, the guilt phase claims contained in his petition for relief from his death sentence under the Post Conviction Relief Act (“PCRA”). After review, the Supreme Court remanded this case back to the PCRA court for an evidentiary hearing limited to two issues pertaining to whether trial counsel rendered ineffective assistance for: (1) failing to show the ballistics evidence purportedly tying appellant to a series of crimes and murders was inconsistent; and (2) impeach an eyewitness’s in-court identification of appellant with the witness’s inability to identify appellant at his preliminary hearing. View "Pennsylvania v. Cousar" on Justia Law

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In 2007, Junius Burno was convicted on two counts of first-degree murder for which he was sentenced to death. In this direct appeal, Burno challenged the admissibility of his confession to the murders, the sufficiency of the evidence, the alleged denial of his right to a speedy trial, and the admissibility of certain evidence establishing an aggravating factor for purposes of the death penalty. The Supreme Court rejected all but one of these challenges on the merits. The Court found merit to Burno’s argument that one of his statements to police was inadmissible because it was obtained during the course of plea negotiations. However, the Court ultimately concluded that the erroneous admission of this statement at trial was harmless. Consequently, the Court affirmed Burno’s death sentence. View "Pennsylvania v. Burno" on Justia Law

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This was a capital direct appeal arising out of Appellant Ricky Smyrnes' participation, with a group of five other individuals, in the kidnapping, torture, and murder of Jennifer Lee Daugherty. The case was a companion one to that of co-perpetrator Melvin Knight. Appellant forced the victim to write a staged suicide note, after which Appellant and Knight dragged her to the bathroom; Knight repeatedly and fatally stabbed her; Appellant slit her wrists (albeit superficially); Appellant and Knight choked her as she lay dying; and her body was placed in a trash can. Appellant and Knight moved the can and body outside to a remote location, where these were discovered the next day. Apparently in light of developing evidence that a disturbance had occurred in Appellant’s apartment, police began to interview the co-perpetrators, and inculpatory statements were obtained. At the penalty hearing, the Commonwealth pursued, and the jury found present, the aggravating circumstances involving torture and a significant history of felony convictions involving the use or threat of personal violence. One or more jurors also found mitigation in the form of “mental illness, childhood physical abuse, [and] childhood sexual abuse.” Upon balancing, however, the jurors unanimously agreed that the aggravating factors outweighed the mitigation and, accordingly, returned the death verdict. This direct appeal followed, in which Appellant presented fifteen claims for relief. Finding no reversible error after review, the Pennsylvania Supreme Court affirmed Appellant's conviction and sentence. View "Pennsylvania v. Smyrnes" on Justia Law

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Appellants Main Line Gardens, Inc. and Coffman Associates, LLC (collectively, “Main Line”), petitioned the Pennsylvania Supreme Court on the issue of whether it was proper for the Commonwealth Court to dismiss its appeal because it did not file briefs at the trial court in support of post-trial motions. The Supreme Court concluded that the Commonwealth Court erred, and thus remanded the case for merits review of the issues raised on appeal. View "Willistown Twp. v. Main Line Gardens" on Justia Law
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The Pennsylvania State Police (“PSP”) appealed a Superior Court judgment holding that section 6111.1(g)(2) of the Uniform Firearms Act, which provided for review by a court of common pleas of a request for the expungement of the PSP’s records of an individual’s involuntary civil commitment under section 7302 (“302”) of the Mental Health Procedures Act (“MHPA”), required a de novo hearing at which clear and convincing evidence must be presented in support of the 302 commitment. The Supreme Court concluded that the Superior Court erred, as the plain language of section 6111.1(g)(2) required a court of common pleas to review only the sufficiency of the evidence to support the 302 commitment, limited to the information available to the physician at the time he or she made the decision to commit the individual, viewed in the light most favorable to the physician as the original decision-maker to determine whether his or her findings are supported by a preponderance of the evidence. Because the Superior Court reviewed the trial court’s decision through an "improper lens," the Supreme Court vacated its decision and remanded this case back to that court for further proceedings. View "In Re Vencil" on Justia Law

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The issue in this workers’ compensation appeal was ultimately whether a notice of compensation payable closely circumscribes the range of health-related conditions to be considered in impairment rating evaluations. The Supreme Court held that physician-examiners must exercise independent professional judgment to make a whole-body assessment of “the degree of impairment due to the compensable injury,” which discernment cannot be withheld on the basis that the physician-examiner believes the undertaking is a more limited one. The order of the Commonwealth Court with respect to this issue was reversed, and the matter remanded for reinstatement of the finding of invalidity rendered by the Worker's Compensation Appeal Board. View "Duffey v. WCAB" on Justia Law

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The issue this case presented for the Pennsylvania Supreme Court's consideration was whether individuals who were not named in an executed testamentary document have standing to bring a legal malpractice action against the testator’s attorney, as purported third-party beneficiaries to the contract for legal services between the testator and his attorney. After review, the Court concluded such individuals do not have standing to sue the testator’s attorney for a breach of contract. The Court therefore reversed the Superior Court and remanded for reinstatement of the trial court’s order granting summary judgment and dismissing the claims. View "Est. of Robert Agnew v. Ross" on Justia Law
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Harrisburg Police Officer Darin Bates and Dauphin County Adult Probation Officer (APO) Richard Anglemeyer were traveling in an unmarked police vehicle in an area known for frequent drug activity when they observed two men conversing on a street corner; one of those men was Appellant Khiri Arter. Notwithstanding Appellant's objection, APO Anglemeyer performed a pat-down search of Appellant and felt a bulge in the right coin pocket of Appellant's pants. APO Anglemeyer reached into Appellant's pocket and retrieved what appeared to be crack cocaine. APO Anglemeyer then "turned the case over to Officer Bates," who arrested Appellant. The Pennsylvania Supreme Court granted allowance of appeal in this matter to determine whether illegally-obtained evidence which was suppressed during criminal proceedings should likewise be suppressed during parole and probation revocation proceedings pursuant to Article I, Section 8 of the Pennsylvania Constitution. The Court concluded that it should, reversed the Superior Court's order affirming the trial court's denial of Appellant's motion to suppress, vacated the order revoking Appellant's parole, and remanded to the trial court for further proceedings. View "Pennsylvania v. Arter" on Justia Law