Justia Pennsylvania Supreme Court Opinion Summaries

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In 2002, a jury convicted Manuel Sepulveda of two counts of first-degree murder and related charges for the deaths of John Mendez and Ricardo Lopez. The jury sentenced Sepulveda to death for each of the murders. At issue in this appeal was whether, following remand from an appellate court with specific instructions, a Post-Conviction Relief Act (PCRA) court may treat new claims raised by the petitioner, which were outside the scope of the remand order, as amending the petitioner’s first, timely PCRA petition. After review, the Pennsylvania Supreme Court concluded that because the PCRA petition had been fully adjudicated, and because the PCRA court was required to proceed in conformance with the remand order, the PCRA court was without authority to permit amendment. View "Pennsylvania v. Sepulveda" on Justia Law

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The issue raised by this appeal centered on whether power was invested in a school reform commission, under a statutory regime designed to facilitate rehabilitation of financially distressed school districts, to unilaterally alter terms and conditions of employment for teachers whose interests were represented by a bargaining unit. In December 2001, the Secretary of Education issued a declaration of financial distress pertaining to the District, and a school reform commission (SRC or “Commission”) was constituted and assumed responsibility for the District’s operations, management, and educational program, per Section 696 of the School Code. Throughout the ensuing years, the SRC and appellee Philadelphia Federation of Teachers, AFT, Local 3, AFL-CIO (the “Union”), negotiated several collective bargaining agreements. The SRC invoked Sections 693(a)(1) of the School Code, as incorporated into Section 696(i), to “make specific limited changes and to implement . . . modified economic terms and conditions for employees in the bargaining units represented by the [Union], consistent with economic terms proposed in negotiations, while maintaining all other existing terms and conditions to the extent required by law[.]” The Commission predicted that the changes would save about $44 million in 2014 through 2015 and $198 million over four years. Ultimately, the resolution purported to cancel the most recent collective bargaining agreement between the District and the Union, to the extent that it continued to govern the parties’ relations. The Commission, the District, and the Department of Education then filed a declaratory judgment action at the Commonwealth Court, asking the Court to uphold the imposition of the new economic terms and conditions as being authorized by applicable law. The Court found that the right of cancellation under Sections 693(a)(1) and 696(i) did not reach such agreements, and that on account of a prescription within Section 693 that “the special board of control shall have power to require the board of directors within sixty (60) days” to implement measures encompassing the cancellation power, the cancellation power could only have been exercised within 60 days after the December 2001 declaration of distress. The Supreme Court reviewed the Commonwealth Court's judgment, and affirmed the outcome, but on differing grounds. The Supreme Court held at least insofar as teachers were concerned, that collective bargaining agreements were “teachers’ contracts” which were excepted from a school reform commission’s cancellation powers. View "Phila. Fed. of Teachers v. SD of Phila." on Justia Law

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In 2008, Scott Kingston was driving home from a party with his then-girlfriend, Jennifer Mroz, who was sitting in the passenger seat. Kingston drove his vehicle off the road and into a ditch. When police officers arrived, Mroz told them that Kingston, who was visibly intoxicated, had been driving the vehicle. The police arrested Kingston and charged him with driving under the influence of alcohol or a controlled substance (“DUI”) and several other Motor Vehicle Code violations. Kingston had three prior DUI convictions. If convicted of a fourth, he faced a mandatory minimum sentence of one-year incarceration. Prior to his trial, Kingston sent Mroz three letters from jail, where he was being held on charges unrelated to this appeal. In his first letter, Kingston asked Mroz to speak to Kingston’s parents, and to find out whether they were willing to testify that Kingston’s father was driving the vehicle on the night of the accident. A few weeks later, Kingston sent Mroz a second letter, asking her to tell "them" that she was driving on the night of the accident, assuring Mroz that if she took the blame for the collision "they" could only "give [her] a fine." Kingston sent Mroz a third letter, again discussing his strategy if Mroz took blame for the accident and "pleading the 5th." Contrary to Kingston’s wishes, Mroz testified that Kingston was driving at the time of the accident. Kingston proceeded to trial. However, due to an administrative oversight, Mroz did not receive notice that the Commonwealth had subpoenaed her to testify at Kingston’s trial until after it had commenced. When she failed to appear on the morning of Kingston’s trial, the court issued a bench warrant for Mroz and proceeded without her. The jury ultimately acquitted Kingston after Kingston’s father falsely testified that he was driving the vehicle on the night in question. The day after Kingston’s trial, Mroz met with a detective and explained the subpoena mix-up. Mroz also told the detective about the letters that Kingston had sent to her from jail. The Commonwealth subsequently charged Kingston with, inter alia, three counts of soliciting perjury and three counts of soliciting to hinder apprehension or prosecution. The question on appeal of the denial of PCRA relief this case, raised under a derivative theory of ineffective assistance of counsel, was whether Section 906 of the Crimes Code proscribed only convictions for two or more distinct inchoate crimes, or whether it also prohibited convictions for two or more counts of the same inchoate crime. The Supreme Court held that Section 906 barred convictions only for multiple distinct inchoate crimes. Because the Superior Court concluded otherwise in remanding for an ineffectiveness hearing, the Supreme Court reversed. View "Pennsylvania v. Kingston" on Justia Law

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An investigation led police to secure a search warrant for a residence in Lancaster County, where appellant Thomas-Lutz-Morrison lived with his mother and brother. A March 2, 2012, search led to the seizure of four computers and an Apple iPhone 4. On the same day, appellant admitted to detectives he had downloaded child pornography files to his computer. An examination revealed 142 child pornography videos and 45 child pornography images on the computer along with 15 child pornography images on appellant’s iPhone. Appellant was charged with 77 counts of sexual abuse of children (possession of child pornography). Appellant entered an open plea of guilty to three counts of possession of child pornography; the remaining charges were withdrawn by the Commonwealth. That same day, appellant was sentenced to consecutive one-year terms of probation on each count. The trial court also notified appellant his convictions subjected him to lifetime registration under SORNA as a Tier III offender. Appellant reserved an objection to that classification, averring the statute was ambiguous, and the only reason it arguably was triggered was because his plea encompassed more than one count. On appeal to the Superior Court, appellant claimed he should be classified as a Tier I offender because his multiple Tier I convictions arose from a single nonviolent course of conduct, and his plea occurred in a single hearing. The Superior Court affirmed in a memorandum opinion. The Pennsylvania Supreme Court granted review of the question whether appellant was properly subject to lifetime reporting under SORNA. Decided after the Supreme Court handed down its decision in "A.S. v. Pa. State Police, ( __A.3d __(2016)), the Court found that, like the "A.S." case, appellant here was charged in a single information arising from the search of his property; he entered court as a first-time offender on those charges and pled guilty to three counts - all Tier I offenses; and there were no direct victims of his crimes, much less multiple direct victims. "As such, the statute requires an act, a conviction, and a subsequent act to trigger lifetime registration for multiple offenses otherwise subject to a fifteen- or twenty-five-year period of registration." The Court reversed the Superior Court and remanded for imposition of a fifteen-year reporting requirement under SORNA. View "Pennsylvania v. Lutz-Morrison" on Justia Law

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In this appeal by the Pennsylvania State Police (PSP) from a grant of mandamus relief, the Pennsylvania Supreme Court revisited an issue concerning the proper construction of the lifetime-registration triggering language “two or more convictions” in Pennsylvania’s former sex offender registration statute, Megan’s Law II (superseded by the Sex Offender Registration and Notification Act (SORNA)). This dispute arose after appellee had completed his sentence for the underlying crimes. Proceeding under a belief he was subject to a ten-year SORNA registration period (a belief shared at sentencing by the court and the prosecutor), appellee filed a Petition for Review in the Nature of a Complaint in Mandamus in the Commonwealth Court’s original jurisdiction shortly before expiration of that period. The petition sought to compel PSP to correct appellee’s sexual offender registration status from lifetime registrant to ten-year registrant and to remove him from the registry when the ten-year period expired. In the course of litigation, the parties attached exhibits including the transcripts from appellee’s guilty plea and sentencing proceedings; ultimately, the parties stipulated discovery was unnecessary and cross-motions for summary judgment were filed. PSP maintained any person with two or more qualifying convictions at the moment of sentencing, such as appellee, was subject to lifetime registration. PSP claimed it properly interpreted and applied the statute and appellee had no right to mandamus relief. After review, the Supreme Court held that the provision, considered in the context of the statutory language as a whole, was amenable to two reasonable constructions. The Court held that the registration statute, which set forth a graduated scheme of registration, encompassed a recidivist philosophy. The Court therefore concluded the statute required an act, a conviction, and a subsequent act to trigger lifetime registration for multiple offenses otherwise triggering a ten-year period of registration. Accordingly, the Court affirmed. View "A.S. v. PA State Police" on Justia Law

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Wayne Mitchell appealed the dismissal of his second petition for relief under the Post-Conviction Relief Act (“PCRA”). Mitchell was convicted of first-degree murder and sentenced to death for the September 10, 1997 murder of his estranged wife, Robin Little. The PCRA court dismissed Mitchell's petition without a hearing, determining the application was untimely made. The Supreme Court agreed and affirmed. View "Pennsylvania v. Mitchell" on Justia Law

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Appellant Terrance Washington was charged with almost two dozen robbery offenses as well as related crimes, and he was convicted by jury trial relative to many of the charges and after pleas concerning others. In 1998, the common pleas court imposed an aggregate sentence of 35 to 70 years’ imprisonment, with the aggregate minimum encompassing multiple mandatory minimum sentences under Section 9712 of the Sentencing Code. Appellant did not initially pursue a direct appeal. He later obtained appellate review nunc pro tunc, however. That appeal was unsuccessful, and the judgments of sentence became final in 2006. Later that year, Appellant filed a timely petition under the Post Conviction Relief Act (PCRA). Notably, Appellant did not raise a Sixth Amendment challenge to the above directives of Section 9712(b). The PCRA court dismissed the petition, and several procedural irregularities ensued, which were addressed in a 2011 order of the Superior Court according Appellant the right to appeal from the dismissal of the post-conviction petition. In 2013, the Supreme Court of the United States issued its Alleyne decision, overruling its prior precedent. The effect of Alleyne was to invalidate a range of Pennsylvania sentencing statutes predicating mandatory minimum penalties upon non-elemental facts and requiring such facts to be determined by a preponderance of the evidence at sentencing. The Superior Court disposed of Appellant’s appeal from the denial of postconviction relief via memorandum opinion in 2015, affirming in relevant part. The Pennsylvania Supreme Court allowed appeal to consider the issue, as framed by Appellant, of “[a]re the mandatory sentences imposed upon petitioner illegal pursuant to Alleyne?” The Court held that Alleyne did not apply retroactively to cases pending on collateral review, and that Appellant’s judgment of sentence, therefore, was not illegal on account of Alleyne. View "Pennsylvania v. Washington" on Justia Law

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In July 2010, appellee William Childs was residing with Michael Beander and Samuel Andrews in Andrews’ house. On July 29, 2010, Andrews invited Bryant Bell (“Victim”) to come over to celebrate Victim’s birthday. All four men were socializing in the residence when Childs and Victim began to argue. Beander and Victim exited the residence and sat on the front steps, while Andrews retreated to his bedroom. Childs remained in the house. But almost immediately, Childs and Victim restarted their argument, trading insults and threats through the screen door. After a few minutes of this back-and-forth, Victim ascended the stairs, picked up a broomstick that had been sitting on the porch, and approached the door. Victim overcame Childs’ efforts to hold the screen door closed and entered the residence. Victim struck Childs with the broomstick several times before Childs stabbed Victim in the chest. Although Childs stabbed Victim only once, Victim died from this wound. Childs was arrested and charged with homicide and possessing instruments of crime (“PIC”). In this appeal by the Commonwealth, the issue presented for the Supreme Court's review was whether Childs was entitled to a castle doctrine jury instruction pursuant to 18 Pa.C.S.A. sec. 505(b)(2.1), which became effective after Childs was charged with the crimes at issue but prior to his trial on those charges. The Court concluded that section 505(b)(2.1) did not affect a person’s right to use deadly force within his or her home, but rather created an evidentiary presumption relevant to the evaluation of such a claim of self-defense, and was therefore a procedural statute. As such, Childs was entitled to that jury instruction. The Court affirmed the Superior Court’s decision vacating Childs’ judgment of sentence and remanded for a new trial. View "Pennsylvania v. Childs" on Justia Law

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In the summer of 1993, Christopher Williams and two codefendants, Theopolis Wilson (also referred to as “Binky” at trial) and Rick Bennett, appeared before a jury, each facing numerous charges related to the shooting deaths of Philadelphia cabdriver William Graham and three young men from New York, Otis Reynolds, Gavin Anderson and Kevin Anderson. James White, a purported eyewitness and accomplice to the murders, testified that Reynolds and the Anderson brothers were in Philadelphia to purchase two AK-47s from Williams. According to White, Williams was the leader of a gang that sold drugs and guns; White was a junior member. Unbeknownst to the victims, the arms deal was a ruse, and Williams planned to rob them when they met. On August 6, 1993, the jury convicted Williams of three counts of first-degree murder and related offenses for which he received three consecutive death sentences. Williams subsequently filed a timely PCRA petition raising twenty-four claims. Relevant here, Williams asserted therein that trial counsel was ineffective for failing to properly cross-examine the Commonwealth’s experts or call a forensic expert in defense, as the physical evidence did not align with White’s testimony about how the shootings occurred and their aftermaths. Before the Supreme Court were two appeals: the Commonwealth's appeal of the order entered by the Philadelphia County Court of Common Pleas granting Williams a new trial pursuant to the Post Conviction Relief Act; and Williams' protective cross-appeal challenging various unfavorable determinations made by the PCRA court on other claims he raised in his PCRA petitions. After careful review, the Court concluded that the record and the law supported the PCRA court’s findings that direct appeal counsel rendered ineffective assistance to Williams, and therefore affirmed. View "Pennsylvania v. Williams" on Justia Law

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This dispute arose out of an attempt to enter a copy of a lost will into probate. Decedent Isabel Wilner died at age 91 in March 2011. Decedent never married. Her intestate heirs were her niece, appellee Dana Wilner and her nephew David Wilner, who was not involved in this litigation. Charles Welles, Esq., a lawyer in Tunkhannock, drafted a will for Decedent, nominating Decedent’s friend Margaret Young as executrix and naming the Decedent's church as the primary beneficiary. Decedent executed the will in June 2007. Attorney Welles made two conformed copies of the will: one copy for his files and gave the other copy was the original will and given to Decedent. Decedent’s live-in caregiver was appellant Linda Baker, a close friend and a cousin by marriage. In April 2010, Attorney Welles prepared two additional documents for Decedent: a codicil which specifically referenced the June 2007 will and changed the executrix from Young to Baker, and a deed transferring ownership of Decedent’s Tunkhannock home to the Pennsylvania church while retaining a life estate. The executed deed was recorded with the county recorder of deeds. As for the codicil, Attorney Welles followed the same procedure as with the will: he made conformed copies, kept one copy for his files, and gave the original and a conformed copy to Decedent. Decedent died on March 16, 2011. Shortly thereafter, Baker went to Decedent’s house to retrieve the will. She discovered that the will had been removed from a downstairs metal box, although other items – including two original codicils and the envelope that had contained the will – were still there. When Baker checked an upstairs safe, she found that all papers had been removed, including a conformed copy of the will. Baker conducted a thorough search of the home but was unable to locate any of the missing items. Without the original will, Baker sought to have Attorney Welles’ conformed copy of the will, together with the original codicils, entered into probate. The court held two evidentiary hearings to determine whether the conformed copy of the will, as produced by Attorney Welles from his files, should have been accepted into probate. During the hearings, the witnesses to the will (members of Attorney Welles' office) testified that they saw Decedent execute the will. However, only one was able to testify to the will’s contents, stating that the terms appearing in the conformed copy accurately reflected the contents of the original will. The Superior Court reversed, concluding that the orphans’ court erred in accepting the conformed copy on the testimony of a single witness. The Supreme Court granted further review to consider the continuing vitality of the two-witness rule and, in particular, whether it properly applied to a will’s contents, as opposed to its execution. Finding that the Superior Court erred in reversing the orphans' court's order, the Supreme Court reinstated the original order. View "In re: Estate of Wilner" on Justia Law
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