Justia Pennsylvania Supreme Court Opinion Summaries

The appellant was convicted of first-degree murder for killing his estranged wife’s 14-month-old son, as well as attempted murder and aggravated assault of his estranged wife’s roommate. The prosecution’s case relied heavily on the testimony of a police officer who witnessed the events. At trial, the appellant represented himself and claimed innocence, alleging a police cover-up. During jury selection, one juror initially indicated on a questionnaire that a family member had been charged with a crime, but then changed the answer to “no.” Decades later, the appellant’s counsel discovered that this juror’s nephew had, in fact, been charged with attempted murder of an infant before the trial, a fact not disclosed during voir dire.The Court of Common Pleas of Dauphin County dismissed the appellant’s third Post Conviction Relief Act (PCRA) petition as untimely, reasoning that the information about the juror’s nephew was available in a 2002 news article and thus not a “new fact.” The court concluded that the appellant failed to show why he could not have discovered this information earlier, and therefore did not meet the requirements for the previously unknown fact exception to the PCRA’s time bar.The Supreme Court of Pennsylvania reviewed the dismissal de novo. It held that the lower court erred by applying a presumption that the appellant knew of the juror’s family connection simply because the information was publicly available. The Supreme Court clarified that the relevant inquiry is whether the appellant actually knew or could have discovered the fact through reasonable diligence, not whether the information was in the public record. The Court vacated the order dismissing the petition and remanded for further proceedings, holding that the appellant was entitled to a hearing to establish whether he met the requirements for the newly discovered fact exception. View "Commonwealth v. Blakeney" on Justia Law

An employee of a roofing subcontractor was severely injured after falling through an uncovered hole while working on a library roof replacement project. The general contractor had contracted with the property owner to perform the roof work and then subcontracted the roofing portion to the injured worker’s employer. The injured worker received workers’ compensation benefits from his direct employer and subsequently filed a negligence lawsuit against the general contractor, seeking damages for his injuries.In the Philadelphia County Court of Common Pleas, the general contractor asserted statutory employer immunity under Pennsylvania’s Workers’ Compensation Act, arguing it was immune from tort liability as a statutory employer. The trial court struck the general contractor’s answer and new matter as untimely and granted the injured worker’s motion to preclude the statutory employer defense at trial. The case proceeded to a jury, which found the general contractor negligent and awarded $5 million to the plaintiff. The trial court denied the general contractor’s post-trial motion for judgment notwithstanding the verdict.On appeal, the Pennsylvania Superior Court vacated the trial court’s judgment and remanded for entry of judgment in favor of the general contractor. The Superior Court held that the general contractor was the injured worker’s statutory employer and thus immune from tort liability, finding all elements of the statutory employer test satisfied and that the defense was not waivable.The Supreme Court of Pennsylvania reviewed whether to overrule prior precedent (Fonner and LeFlar) regarding statutory employer immunity and waiver, and whether the Superior Court properly applied the statutory employer test. The Supreme Court reaffirmed its prior holdings that a general contractor’s statutory employer immunity does not depend on actual payment of workers’ compensation benefits and that the defense is jurisdictional and not waivable. However, it found the Superior Court erred by exceeding its scope of review and remanded the case to the trial court to determine, after appropriate proceedings, whether the general contractor satisfied the disputed elements of the statutory employer test. View "Yoder v. McCarthy Const." on Justia Law

The case concerns an individual who was arrested twice for suspicion of driving under the influence (DUI) in Pennsylvania. The first arrest led to charges, while the second arrest did not result in charges until several months later. In the interim, the individual applied for admission to the county’s Accelerated Rehabilitative Disposition (ARD) program for the first DUI. The ARD application required disclosure of prior convictions, prior ARD participation, and any pending criminal charges, but did not ask about uncharged arrests. The applicant truthfully stated he had no pending charges at the time of the application.After the applicant was admitted to the ARD program, the Commonwealth learned of the second DUI charge and moved to revoke his ARD participation, arguing he violated program conditions by not disclosing the prior arrest. The Adams County Court of Common Pleas revoked his ARD participation, initially citing the new charges and later referencing “deception by omission.” The applicant was subsequently convicted and sentenced for the first DUI. The Pennsylvania Superior Court affirmed, reasoning that failing to disclose the second arrest, even if uncharged, undermined the spirit and intent of the ARD program, and relied on prior cases where omissions or misrepresentations justified ARD revocation.The Supreme Court of Pennsylvania reviewed the case and held that revocation of ARD participation must be based on violation of a specified condition of the program, not on implied conditions or the general “spirit” of the program. The Court found that the applicant answered all questions on the ARD application truthfully, as there were no pending charges at the time, and the application did not require disclosure of uncharged arrests. Therefore, the trial court erred in revoking ARD participation, and the Supreme Court reversed the Superior Court’s decision. View "Commonwealth v. Jenkins" on Justia Law

A patient was involuntarily admitted to a hospital for mental health treatment due to dementia-related aggression. During his stay, he developed and experienced worsening pressure ulcers. After being transferred to another facility, he died ten days later. The estate of the patient filed a wrongful death and survival action against the hospital, alleging negligence and corporate negligence in the care and treatment of the patient’s pressure ulcers, claiming these injuries contributed to his decline and death.The Lehigh County Court of Common Pleas granted the hospital’s motion for judgment on the pleadings, finding that the hospital’s care for the pressure ulcers was incidental to the patient’s mental health treatment. The court concluded that, under Section 114 of the Pennsylvania Mental Health Procedures Act (MHPA), the hospital was immune from liability for ordinary negligence because the care provided was coincident to mental health treatment, and the complaint did not allege willful misconduct or gross negligence. The Superior Court of Pennsylvania affirmed this decision, holding that the immunity provision of the MHPA applied to the hospital’s conduct.The Supreme Court of Pennsylvania reviewed whether the MHPA’s immunity provision applied to the hospital’s treatment of the patient’s physical ailments during his mental health admission. The Court held that the MHPA’s immunity provision covers not only treatment directly related to mental illness but also medical care coincident to mental health treatment, including foreseeable physical complications like pressure ulcers. Because the estate’s complaint alleged only ordinary negligence and not gross negligence or willful misconduct, the Court affirmed the Superior Court’s order granting judgment on the pleadings in favor of the hospital. View "Wunderly v. Saint Luke's Hosp." on Justia Law

A homebuyer entered into an agreement to purchase a property in Titusville, Pennsylvania, and, before completing the purchase, orally contracted with a home inspector to perform an inspection. The inspector delivered a report that did not disclose any structural or foundational issues. Relying on this report, the buyer purchased the property. The following winter, a burst pipe led to the discovery of significant defects, including the absence of a proper foundation and improper ductwork, which had not been disclosed in the inspection report. The buyer filed suit against the inspector more than two years after the report was delivered, alleging violations of the Pennsylvania Home Inspection Law, breach of contract, and violations of the Unfair Trade Practices and Consumer Protection Law.The Court of Common Pleas of Crawford County overruled most of the inspector’s preliminary objections and denied a motion for judgment on the pleadings, finding ambiguity in the statute governing the time to bring actions arising from home inspection reports. The trial court reasoned that the statute could be interpreted as either a statute of limitations or a statute of repose and declined to grant judgment for the inspector. On appeal, the Superior Court reversed, holding that the statute in question was a statute of repose, not a statute of limitations, and that all of the buyer’s claims were time-barred because they were filed more than one year after the inspection report was delivered.The Supreme Court of Pennsylvania reviewed whether the relevant statutory provision, 68 Pa.C.S. § 7512, is a statute of repose or a statute of limitations. The Court held that the statute is a statute of repose, barring any action to recover damages arising from a home inspection report if not commenced within one year of the report’s delivery, regardless of when the claim accrues. The Court affirmed the Superior Court’s judgment. View "Gidor v. Mangus" on Justia Law

Christopher Toland was sentenced in 1993 to a lengthy prison term for rape, kidnapping, and related offenses, making him eligible for parole in 2004. Between 2004 and 2020, the Pennsylvania Parole Board denied him parole fourteen times, often contrary to recommendations from the Department of Corrections. Toland filed a petition for review in the Commonwealth Court of Pennsylvania, seeking mandamus relief and alleging constitutional violations in the Board’s parole denials from 2017, 2018, and 2019. He claimed the Board relied on false information, acted arbitrarily, and applied parole standards retroactively in violation of ex post facto prohibitions.The Commonwealth Court overruled the Parole Board’s preliminary objections to Toland’s claims, allowing discovery to proceed. When Toland requested documents related to his parole eligibility, the Parole Board objected, citing its own regulation (37 Pa. Code § 61.2) that designates its records as “private, confidential and privileged.” The Commonwealth Court rejected the Board’s objections, finding that Toland, as the beneficiary of the privilege, could waive it. The Board then filed an interlocutory appeal.The Supreme Court of Pennsylvania reviewed the case and affirmed the Commonwealth Court’s order, but on a different basis. The Supreme Court held that the Parole Board does not have the authority to create an evidentiary privilege through its own regulation. Therefore, Section 61.2 does not establish a privilege that can be invoked to prevent disclosure of documents in discovery. The Court clarified that only privileges created by the legislature, the constitution, or the common law are recognized in Pennsylvania courts, and no such privilege exists under Section 61.2. The Supreme Court’s disposition was to affirm the lower court’s order. View "Toland v. PBPP" on Justia Law

The appellant pleaded guilty in 2015 to driving under the influence and resisting arrest, receiving a sentence of incarceration followed by probation. While serving probation for this 2015 case, he was arrested in 2018 for aggravated assault. After his mother posted bail on the new charges, a probation detainer from the 2015 case kept him in custody. He later pleaded guilty to aggravated assault in the 2018 case and was sentenced to a term of imprisonment. The trial court did not credit him for all the time he spent in custody before sentencing, specifically the period he was held solely on the probation detainer after bail was posted in the 2018 case.The Lackawanna County Court of Common Pleas, acting as the PCRA court, granted partial relief by awarding credit only for the period after the detainer was lifted, reasoning that the earlier period of confinement was solely due to the probation detainer in the 2015 case, for which only a probationary sentence was ultimately imposed. The Pennsylvania Superior Court affirmed, holding that the appellant was not entitled to credit for time spent in custody on the probation detainer because no prison sentence was imposed in the 2015 case, and the time was not attributable to the new charges after bail was posted.The Supreme Court of Pennsylvania reviewed the statutory language of 42 Pa.C.S. § 9760(1) and held that a defendant is entitled to credit against a new prison sentence for all time spent in custody as a result of the conduct underlying the new charge, even if the confinement was due to a probation detainer from an earlier case, so long as the conduct leading to the detainer is the same as that underlying the new charge. The Court reversed the Superior Court’s order and remanded for further proceedings to determine if relief could still be awarded. View "Commonwealth v. Phillips" on Justia Law

Several voters in Washington County, Pennsylvania, submitted mail-in ballots for the 2024 Primary Election that contained obvious errors, such as missing signatures or dates on the declaration envelope, or missing secrecy envelopes. Under a previous policy, the county board of elections notified voters of such defects and allowed them to correct the errors or vote provisionally. However, in April 2024, the board adopted a new policy eliminating notice and cure procedures. Instead, all returned mail-in ballots, including those with disqualifying errors, were coded identically in the state’s SURE system, which triggered an email to voters stating their ballot had been received and that they could not vote at the polls, regardless of whether their ballot was valid. As a result, voters whose ballots were set aside for errors were not informed of the disqualification and did not attempt to vote provisionally.The Washington County Court of Common Pleas found that the board’s policy violated voters’ procedural due process rights under the Pennsylvania Constitution by failing to provide notice that their ballots would not be counted, thus depriving them of the opportunity to challenge the decision or vote provisionally. The court issued an injunction requiring the board to notify affected voters, accurately code ballots in the SURE system, and ensure poll books reflected that such voters had not “voted,” allowing them to cast provisional ballots. The Commonwealth Court affirmed, holding that the right to vote and the statutory right to cast a provisional ballot are protected liberty interests, and that the board’s policy risked erroneous deprivation of those rights.The Supreme Court of Pennsylvania affirmed in large part, holding that the right to vote and the statutory right to cast a provisional ballot when a mail-in ballot is void are protected liberty interests under the Pennsylvania Constitution. The court held that due process requires county boards to provide accurate notice—via correct SURE system coding—when a mail-in ballot is segregated for a disqualifying error, so affected voters have the opportunity to vote provisionally. The court vacated the requirement for additional notice beyond accurate SURE coding and clarified that the right to challenge under 25 P.S. §3157 does not require pre-canvass challenges. The injunction otherwise remains in effect. View "Center for Coalfield Justice v. Washington County Board of Elections" on Justia Law

The case concerns James Smith, who was charged with multiple counts of child sexual assault involving two minor victims, the daughters of a friend, in Philadelphia. Before trial, Smith requested that the jury panel be asked during voir dire whether they were more likely to believe the testimony of a child alleging sexual abuse because they did not believe a child could lie about such abuse. The trial court declined to ask this specific question but did inform jurors about the nature of the charges, asked about their ability to be impartial, and conducted individual voir dire regarding experiences with sexual assault or child abuse, dismissing several jurors for cause based on their responses.Smith was convicted on all counts, including rape of a child, unlawful contact with a minor, corruption of minors, involuntary deviate sexual intercourse with a child, and aggravated indecent assault of a person less than thirteen years of age. He appealed to the Superior Court of Pennsylvania, arguing that the trial court erred in refusing his proposed voir dire question and that the evidence was insufficient to support his convictions for unlawful contact with a minor. The Superior Court affirmed the trial court’s judgment, finding no error in the voir dire process and concluding that Smith’s communications with the victims met the statutory requirements for unlawful contact.On further appeal, the Supreme Court of Pennsylvania reviewed two issues: whether the trial court abused its discretion in refusing to ask the proposed voir dire question about bias toward child victim testimony, and whether the Superior Court had impermissibly expanded the scope of criminal liability under the unlawful contact statute. The Supreme Court held that, on the record presented, the trial court did not abuse its discretion in refusing the voir dire question. Regarding the unlawful contact conviction, the Supreme Court vacated the Superior Court’s judgment and remanded for reconsideration in light of its recent decision in Commonwealth v. Strunk, which clarified the scope of the relevant statute. View "Commonwealth v. Smith" on Justia Law

Several minors were injured at trampoline parks operated by Sky Zone in Philadelphia. In each instance, only one parent signed a “Participation Agreement, Release and Assumption of the Risk” on behalf of the minor child. The Agreement included a release of liability and an arbitration provision requiring all claims to be resolved by arbitration, waiving the right to a jury trial. After the injuries, lawsuits were filed by both the injured minors’ non-signing parents and the minors themselves, seeking damages for the injuries sustained.The Court of Common Pleas of Philadelphia County reviewed the cases and denied Sky Zone’s petitions to compel arbitration. The trial courts found that the Agreements were enforceable only against the signing parent, not the non-signing parent or the minor child. The courts reasoned that there was no evidence of agency between spouses that would allow one parent to bind the other, and that parents do not have the legal authority to waive a minor’s right to pursue personal injury claims or to bind a minor to an arbitration agreement. The Superior Court of Pennsylvania affirmed these rulings, emphasizing that agency cannot be inferred from marriage alone and that parents, as natural guardians, lack authority over a minor’s property interests, including legal claims, without court approval.The Supreme Court of Pennsylvania reviewed the consolidated appeals. It held that the arbitration agreement signed by one parent is not enforceable against the non-signing parent or the minor child. The Court found that a marital relationship alone does not create an agency relationship, and there was no evidence of express, implied, apparent, or estoppel-based agency. Additionally, the Court held that parents, as natural guardians, lack inherent authority to bind their minor children to arbitration agreements that forfeit the right to a judicial forum and the procedural protections afforded to minors in court. The orders of the Superior Court were affirmed. View "Santiago v. Philly Trampoline Park" on Justia Law