Justia Pennsylvania Supreme Court Opinion Summaries

In 2007, Richard Roland Laird was sentenced to death following his retrial for first-degree murder, having originally been convicted and sentenced to death in 1988 for the same offense. Laird's most recent appeal challenges the denial of his latest Post Conviction Relief Act (PCRA) petition as untimely. He requested the Pennsylvania Supreme Court to create an equitable exception to the PCRA’s time-bar, citing the decision in Commonwealth v. Bradley, and also argued that Article 7 of the International Covenant on Civil and Political Rights (ICCPR) precluded the dismissal of his petition as untimely.The Court of Common Pleas of Bucks County denied Laird’s PCRA petition, finding it untimely and not meeting any statutory exceptions. The court also rejected Laird’s claims on the merits, including ineffective assistance of counsel (IAC) claims and an illegal sentencing claim. Laird’s appeal to the Pennsylvania Supreme Court followed.The Pennsylvania Supreme Court affirmed the lower court’s decision, holding that Bradley did not establish an equitable exception to the PCRA’s time-bar and that its rationale could not be extended to create one. The court emphasized that the PCRA’s time limitations are jurisdictional and not subject to equitable principles. Additionally, the court held that the ICCPR could not be invoked to circumvent the PCRA’s timeliness requirements, reaffirming that exceptions to the PCRA’s time-bar are strictly limited to those set forth in the statute.Thus, the Pennsylvania Supreme Court affirmed the order denying Laird’s PCRA petition as untimely, concluding that neither Bradley nor the ICCPR provided a basis to bypass the PCRA’s jurisdictional time-bar. View "Commonwealth v. Laird" on Justia Law

A police detective was charged with multiple criminal offenses, including unsworn falsification to authorities, tampering with or fabricating physical evidence, tampering with public records or information, and obstructing administration of law or other governmental function. The charges stemmed from allegations that the detective assisted his cousin in stalking a woman and attempted to cover up his misconduct by using police databases to obtain her information and then lying about it during an internal affairs investigation.The Municipal Court of Philadelphia dismissed the charges against the detective for lack of evidence. The Commonwealth refiled the charges, but the Court of Common Pleas of Philadelphia County also dismissed them, concluding that the Commonwealth failed to establish a prima facie case. The Superior Court of Pennsylvania affirmed the dismissal, agreeing that the evidence was insufficient to support the charges.The Supreme Court of Pennsylvania reviewed the case and reversed the Superior Court's decision. The Court held that the Commonwealth had presented sufficient evidence to establish a prima facie case for each of the charges. The Court found that the detective's actions, including his false statements during the internal affairs investigation and the suspicious addition of a second folder to the homicide file, supported the charges. The Court emphasized that at the preliminary hearing stage, the evidence must be viewed in the light most favorable to the Commonwealth, and all reasonable inferences must be drawn in its favor. The case was remanded for further proceedings. View "Commonwealth v. Williams" on Justia Law

Daniel Garcia purchased cloth facemasks from several retail stores in late 2020. The retailers collected sales tax on these masks, which Garcia believed to be nontaxable. Garcia filed a class action complaint in the Court of Common Pleas of Allegheny County against the retailers, alleging that they collected sales tax on items they knew or should have known were nontaxable, violating the Unfair Trade Practices and Consumer Protection Law (UTPCPL).The Court of Common Pleas overruled the retailers' preliminary objections, which argued that the complaint was legally insufficient. The Superior Court granted the retailers permission to appeal and reversed the trial court's order. The Superior Court concluded that the collection of sales tax did not occur "in the conduct of any trade or commerce" as contemplated by the UTPCPL. The court reasoned that the collection of sales tax is a statutory obligation distinct from the conduct of trade or commerce and that merchants act as agents of the Commonwealth when collecting sales tax.The Supreme Court of Pennsylvania reviewed the case and affirmed the Superior Court's decision. The court held that a merchant’s collection of sales tax does not occur "in the conduct of any trade or commerce" under the UTPCPL. The court emphasized that the collection of sales tax is a statutory obligation imposed on merchants, who act as agents of the Commonwealth, and is distinct from their commercial activities. The court also noted that the Pennsylvania Code requires a clear separation between the advertising of a product’s price and the sales tax due, further supporting the conclusion that tax collection is not part of trade or commerce. View "Garcia v. Foot Locker" on Justia Law

Jennifer Jackiw, while working for Soft Pretzel Franchise, sustained an injury that led to the amputation of her right forearm. The employer acknowledged liability, and at the time of the injury, Jackiw's average weekly wage was $322.05. The parties agreed that the injury was a "specific loss" under the Pennsylvania Workers' Compensation Act, entitling her to a healing period of up to 20 weeks followed by 370 weeks of compensation. However, they disagreed on how to calculate the weekly benefit amount for the 370 weeks.A workers' compensation judge (WCJ) concluded that Jackiw's benefit should be calculated according to the formula for total disability under Section 306(a) of the Act. The Workers' Compensation Appeal Board (WCAB) affirmed this decision, despite acknowledging arguments that the specific-loss benefits should be calculated differently. The WCAB felt bound by the Commonwealth Court's decision in Walton v. Cooper Hosiery Co., which had interpreted the Act to harmonize benefits for specific loss and total disability.The Commonwealth Court, in a divided en banc panel, affirmed the WCAB's decision, applying the rule of stare decisis and agreeing with the interpretation in Walton. The dissenting judges argued that the statutory text provided more generous benefits for specific-loss injuries than for total disability without the loss of a body part.The Supreme Court of Pennsylvania reviewed the case to determine the correct statutory formula for calculating workers' compensation benefits for the loss of a body part. The court concluded that the plain text of the statute indicated that specific-loss benefits should be calculated under Section 306(c), not Section 306(a). The court vacated the Commonwealth Court's order and remanded the case for further proceedings consistent with this interpretation. View "Jackiw v. Soft Pretzel Franchise" on Justia Law

A group of individuals and West Rockhill Township challenged the Pennsylvania Department of Environmental Protection (DEP) regarding its approval of a compressor station project by Adelphia Gateway, LLC. The DEP's approval was part of the federal Clean Air Act (CAA) and the Pennsylvania Air Pollution Control Act (APCA) enforcement. The challengers sought review from the Pennsylvania Environmental Hearing Board (EHB), which dismissed the appeals, citing the Third Circuit's exclusive jurisdiction under the Natural Gas Act (NGA) for such federal law-related decisions.The Commonwealth Court of Pennsylvania reversed the EHB's dismissal, holding that the EHB had jurisdiction to review the DEP's decision. The court reasoned that an appeal to the EHB is not a "civil action" under the NGA, which grants the Third Circuit exclusive jurisdiction over civil actions challenging state agency decisions under federal law. The court distinguished administrative proceedings from civil actions, noting that EHB appeals are administrative in nature and not subject to the NGA's jurisdictional provision.The Supreme Court of Pennsylvania reviewed the case and affirmed the Commonwealth Court's decision. The court held that the EHB has jurisdiction to review the DEP's permitting decisions under the CAA and APCA. It concluded that EHB appeals are not "civil actions" as defined by the NGA, and thus, the Third Circuit's exclusive jurisdiction does not preempt EHB's review. The court also emphasized that the DEP's decisions are not final until the opportunity for EHB review has passed, aligning with Pennsylvania's statutory framework and the federal Clean Air Act's delegation of authority to state agencies. The case was remanded to the EHB for substantive review of the challengers' appeals. View "Cole v. DEP" on Justia Law

A group of individuals and West Rockhill Township challenged the Pennsylvania Department of Environmental Protection's (DEP) approval of a compressor station project by Adelphia Gateway, LLC. The DEP's approval was issued under the federal Clean Air Act (CAA) and Pennsylvania's Air Pollution Control Act (APCA). The challengers sought review of the DEP's decision before the Pennsylvania Environmental Hearing Board (EHB).The EHB dismissed the appeals, agreeing with Adelphia that the United States Court of Appeals for the Third Circuit had exclusive jurisdiction over the matter under the Natural Gas Act (NGA), which grants federal courts original and exclusive jurisdiction over civil actions for the review of state administrative agency decisions made pursuant to federal law.The Commonwealth Court of Pennsylvania reversed the EHB's dismissal, holding that the EHB had jurisdiction to hear the appeals. The court reasoned that an appeal to the EHB is not a "civil action" as defined by the NGA, and thus, the EHB's review was not preempted by federal law. The court also noted that the DEP's decision was not final until the opportunity for EHB review had expired or been exhausted.The Supreme Court of Pennsylvania affirmed the Commonwealth Court's decision. The court held that the EHB has jurisdiction to review the DEP's permitting decisions under the CAA and APCA. The court found that the EHB's review process is an administrative proceeding, not a civil action, and therefore, it does not fall under the exclusive jurisdiction of the federal courts as outlined in the NGA. The court also emphasized that the DEP's decision is not final until the EHB review process is complete or the time to seek such review has expired. View "West Rockhill Twp v. DEP" on Justia Law

Appellants CKHS, Inc. and The Foundation for Delaware County sought a preliminary injunction to prevent Appellees Prospect Medical Holdings, Inc. and Prospect Crozer, LLC from converting Delaware County Memorial Hospital from an emergency and acute care facility to a behavioral health hospital. The asset purchase agreement (APA) between the parties included clauses requiring Prospect to maintain key service lines, including emergency medicine, for five years and to consult with a local advisory board before making significant changes after that period. Additionally, the APA stipulated that any breach would cause irreparable damage.The Delaware County Court of Common Pleas granted the preliminary injunction, finding that Appellants demonstrated the necessary prerequisites, including irreparable harm. The court relied on the APA's irreparable harm clause and expert testimony from Melissa Lyon, who testified that removing healthcare access points from a community almost always negatively impacts health outcomes, particularly for socioeconomically disadvantaged and elderly populations.The Commonwealth Court reversed the trial court's order, concluding that the trial court abused its discretion by finding irreparable harm based on speculative and hypothetical evidence. The Commonwealth Court held that the APA's irreparable harm clause alone was insufficient and required concrete evidence of harm, which it found lacking in Lyon's testimony.The Supreme Court of Pennsylvania reviewed the case and determined that the Commonwealth Court misapplied the appellate standard of review, which requires a highly deferential approach to the trial court's decision. The Supreme Court found that the trial court had apparently reasonable grounds to issue the preliminary injunction based on Lyon's testimony and the APA's irreparable harm clause. Consequently, the Supreme Court reversed the Commonwealth Court's order and remanded the case for further proceedings to address the remaining factors for preliminary injunctive relief. View "CKHS, Inc. v. Prospect Med Hldgs, Inc." on Justia Law

William Herold worked for the University of Pittsburgh as a stationary engineer from 1976 to 2004, during which he was exposed to asbestos. He later became a foreman, a position without asbestos exposure, and retired in 2015. In 2019, Herold was diagnosed with mesothelioma, attributed to his asbestos exposure, and he died in 2022. His estate filed a common law negligence action against the University and other defendants in the Allegheny County Court of Common Pleas.The trial court denied the University’s motion for summary judgment, which argued that the Occupational Disease Act (ODA) provided the exclusive remedy for Herold’s claim. The court found that Herold’s mesothelioma, manifesting more than four years after his last exposure, was not compensable under the ODA. The Commonwealth Court affirmed, holding that the ODA’s exclusivity provision did not apply to Herold’s non-compensable claim, allowing the common law action to proceed.The Supreme Court of Pennsylvania reviewed the case, focusing on whether the ODA’s exclusivity provision barred Herold’s common law action. The Court held that the ODA’s exclusivity provision extends only to claims asserting compensable disability or death, defined as occurring within four years of the last employment. Since Herold’s mesothelioma manifested beyond this period, the exclusivity provision did not apply, and the common law action was permissible. The Court also determined that the doctrine of primary jurisdiction did not require the claim to be adjudicated by the workers’ compensation authorities, as the issues were not complex or technical.The Supreme Court of Pennsylvania affirmed the Commonwealth Court’s decision, allowing the common law negligence action to proceed in the trial court. View "In Re: Estate of W. Herold" on Justia Law

William Roberts was convicted of statutory sexual assault, sexual assault, corruption of the morals of a minor, and indecent assault in 2005. He was sentenced to one and a half to three years in prison and required to register as a sexual offender for life under Megan’s Law III. Roberts complied with his registration obligations until 2019 but failed to report in 2020. The Pennsylvania State Police (PSP) discovered that Roberts no longer lived at his registered address and had not updated his information, leading to his arrest and charges for failing to comply with registration requirements.The Court of Common Pleas of Fayette County convicted Roberts of two counts of failure to comply with registration requirements and sentenced him to five to ten years in prison. Roberts appealed, arguing that the Commonwealth failed to prove he knew he was required to register. The Superior Court affirmed the conviction, holding that the crime occurred when Roberts knowingly failed to register or verify his residence, regardless of whether he knew he was required to do so.The Supreme Court of Pennsylvania reviewed the case to determine if the Commonwealth must prove that a sexual offender knew of their registration obligations to convict them of failure to comply. The Court held that the Commonwealth must prove the offender knew of their SORNA obligations. However, the Court found sufficient evidence that Roberts knew of his lifetime registration requirement, as he had signed forms acknowledging this multiple times. Thus, the Supreme Court affirmed the judgment of sentence. View "Commonwealth v. Roberts" on Justia Law

On May 8, 2020, Sergeant Aaron Scott and Officer Samuel Greco of the Frazer Township Police Department responded to a rollover vehicle accident. They found Jarren Crosby and a female companion near the overturned vehicle. Crosby admitted to driving, and the officers detected signs of marijuana use. Crosby was unsteady and had slurred speech. When the officers detained him for a DUI investigation, Crosby became agitated and resisted arrest. Officer Greco attempted to handcuff Crosby, who resisted by pulling away and screaming. Greco then tackled Crosby and used a taser to subdue him. Crosby was charged with multiple offenses, including DUI and resisting arrest.The Court of Common Pleas of Allegheny County convicted Crosby of DUI, resisting arrest, and careless driving, while acquitting him of other charges. Crosby was sentenced to four days in the DUI Alternative to Jail Program and fifteen months’ probation. Crosby’s post-sentence motions were denied, and he appealed, challenging the sufficiency of the evidence for his resisting arrest conviction.The Superior Court of Pennsylvania affirmed the trial court’s judgment, holding that the evidence was sufficient to support Crosby’s conviction for resisting arrest. The court noted that Crosby’s resistance required substantial force to overcome, as Officer Greco had to tackle him and use a taser.The Supreme Court of Pennsylvania reviewed the case and affirmed the Superior Court’s decision. The court clarified that the offense of resisting arrest under the second variant of the statute involves the defendant employing means that justify or require substantial force to overcome the resistance. The court held that Officer Greco’s tackle of Crosby constituted substantial force, and thus, the evidence was sufficient to support Crosby’s conviction for resisting arrest. The judgment of the Superior Court was affirmed, and the case was remanded to correct a scrivener’s error in the sentencing order. View "Commonwealth v. Crosby" on Justia Law