Justia Pennsylvania Supreme Court Opinion Summaries

Michael Jones was convicted of attempted murder and related charges after an incident where he and his codefendants, Syheed Wilson and Keirsten Carroll, were involved in a shooting of a cab driver, Alex Destin. Jones directed the cab driver and then shot him, while Wilson also shot the driver. The three were identified through surveillance footage and arrested. Wilson gave a statement to the police implicating Jones as the shooter.At trial, Jones objected to the admission of Wilson’s statement, arguing it violated the Sixth Amendment Confrontation Clause as established in Bruton v. United States. The trial court overruled the objection, and the jury was instructed to consider each defendant’s statement only against the one who made it. Jones was found guilty on all counts and sentenced to twenty to forty years in prison. The Superior Court affirmed the conviction, reasoning that the redacted statement, which referred to Jones as “my friend,” did not violate the Confrontation Clause because it did not explicitly name him and required linkage with other evidence to be incriminating.The Supreme Court of Pennsylvania reviewed the case, focusing on whether the admission of Wilson’s redacted statement violated Bruton. The court noted that the statement, though redacted to refer to Jones as “my friend,” still directly incriminated him by describing him in a way that the jury could easily identify him, especially since the jury was shown surveillance footage and still images identifying Jones. The court concluded that the statement violated Bruton’s prohibition against admitting a non-testifying codefendant’s confession that directly implicates the defendant.The Supreme Court of Pennsylvania vacated the Superior Court’s order and remanded the case for the Superior Court to determine whether the Bruton violation amounted to harmless error. View "Commonwealth v. Jones" on Justia Law

The case involves a petition challenging the public release of a grand jury report by the 30th County Investigating Grand Jury. The petitioner argued that the report did not meet the statutory definition of an "investigatory grand jury report" under the Investigatory Grand Jury Act (IGJA) and that the supervising judge erred in ordering its release. The petitioner also contended that the report's criticism of named, unindicted individuals violated their due process rights and the fundamental right to reputation under the Pennsylvania Constitution.The Philadelphia County Court of Common Pleas initially accepted the report and ordered its public release. The supervising judge provided notice and an opportunity to respond to some, but not all, named, unindicted individuals criticized in the report. The petitioner, along with others, sought to have the report permanently sealed or redacted. The supervising judge made some redactions but ultimately ordered the report to be unsealed.The Supreme Court of Pennsylvania reviewed the case and concluded that the report did not satisfy the IGJA's definition of an "investigatory grand jury report" because it neither related to organized crime or public corruption nor proposed recommendations for legislative, executive, or administrative action in the public interest. The court found that the report focused on punishing specific individuals and providing answers to the deceased-accused's family, rather than addressing broader public concerns.The court also determined that due process requires notice and an opportunity to respond for all named, unindicted individuals criticized in a grand jury report. The supervising judge's failure to provide such notice to all criticized individuals was deemed an error. Consequently, the Supreme Court vacated the supervising judge's order and remanded the case with instructions to permanently seal the report. View "In Re: The Thirtieth County Investigating Grand Jury" on Justia Law

Lisa Smith, the appellant, lived with her boyfriend, Keiff King, and her four-year-old son, Tahjir, in a home in Abington Township, Pennsylvania. On January 22, 2018, after Tahjir spilled cereal, he was subjected to severe punishment by Smith and King, including being forced to hold difficult positions and being beaten. Tahjir was also placed in a hot shower, resulting in severe burns. Later, when Tahjir showed signs of severe distress, Smith and King delayed seeking medical help. Eventually, Smith called 911, but Tahjir was pronounced dead at the hospital. An autopsy revealed that Tahjir died from "crush syndrome" due to severe beatings and burns.Smith and King were charged with first-degree murder, endangering the welfare of a child, and criminal conspiracy. Smith's motion to suppress her statements to the police was partially granted, excluding statements made before receiving Miranda warnings. At trial, King's redacted statement, which replaced Smith's name with feminine pronouns, was admitted. The trial court instructed the jury to consider King's statement only against him. Both Smith and King were convicted, and Smith was sentenced to life in prison without parole, plus additional years.The Supreme Court of Pennsylvania reviewed whether Smith's Sixth Amendment right to confrontation was violated by admitting King's redacted statement. The court held that there was no violation, as the redacted statement did not directly or powerfully implicate Smith in the crime. The court emphasized that the statement did not identify Smith as a participant in the abuse and that the jury was properly instructed to consider the statement only against King. Consequently, the court affirmed the Superior Court's decision, upholding Smith's conviction and sentence. View "Commonwealth v. Smith" on Justia Law

The case involves Jason Andrew Lear, who faced criminal charges for theft and assault in Montgomery County, Pennsylvania. The charges were filed in May, June, and July 2020. Due to the COVID-19 pandemic, the Montgomery County Court of Common Pleas suspended criminal trials and implemented strict protocols, delaying Lear's trial. His trial was eventually scheduled for November 1, 2021, well beyond the 365-day limit set by Pennsylvania Rule of Criminal Procedure 600.The Montgomery County Court of Common Pleas denied Lear's motion to dismiss based on Rule 600, reasoning that the delay was due to the judicial emergency caused by the pandemic. Lear was convicted and sentenced to five to twelve years in prison. He appealed to the Superior Court, which vacated his sentence and remanded the case for a hearing to determine if the Commonwealth had acted with due diligence during the delay.The Supreme Court of Pennsylvania reviewed whether Rule 600 requires the Commonwealth to demonstrate due diligence during a judicial emergency. The Court held that the delays caused by the COVID-19 pandemic and related court closures do not fall under the "judicial delay" category requiring a due diligence assessment. Instead, these delays are considered "other periods of delay" under Rule 600(C)(1) and are excludable from the 365-day computation without assessing the Commonwealth's diligence. The Court reversed the Superior Court's decision, ruling that no Rule 600 violation occurred and no hearing was necessary. View "Commonwealth v. Lear" on Justia Law

The case involves Michael L. Strunk, who was convicted of multiple sexual offenses against a minor, including unlawful contact with a minor. The victim testified that Strunk assaulted her on three separate occasions, each time while she pretended to be asleep. During these assaults, Strunk engaged in various forms of physical contact, such as fondling her and removing her clothing, but there was no evidence of verbal or non-verbal communication to facilitate the assaults.Strunk was convicted in the Dauphin County Court of Common Pleas and sentenced to an aggregate term of 17 to 35 years’ incarceration. He filed post-sentence motions challenging the weight and sufficiency of the evidence, which were denied. On appeal, the Superior Court affirmed the conviction, concluding that the physical contact beyond the assaults themselves was sufficient to establish a violation of Section 6318 of the Pennsylvania Crimes Code, which criminalizes unlawful contact with a minor.The Supreme Court of Pennsylvania reviewed the case and focused on whether the term "in contact with" under Section 6318 includes non-communicative conduct. The Court concluded that the statute is intended to criminalize communicative behavior aimed at facilitating sexual exploitation, not merely physical contact. The Court found that the Superior Court erred in its interpretation by equating physical contact with communication. Since there was no evidence that Strunk communicated with the victim to facilitate the assaults, the Supreme Court vacated his conviction for unlawful contact with a minor. This decision did not affect the aggregate sentence, as the sentence for this conviction was imposed concurrently with other sentences. View "Commonwealth v. Strunk" on Justia Law

In 2016, voters in Donegal Township, Washington County, Pennsylvania, decided to increase the number of members on the township’s board of supervisors from three to five. Subsequently, in 2020, the voters opted to reduce the number back to three. This led to a legal dispute involving Richard Martin, Jr., Richard Fidler, and Tammy Iams, who were elected to the five-member board but faced shortened terms due to the reduction.The Court of Common Pleas of Washington County initially dismissed the action brought by Martin, Fidler, and Iams, who challenged the constitutionality of Section 402(e) of the Second Class Township Code. The Commonwealth Court partially reversed this decision, ruling that Section 402(e) was unconstitutional as applied to Martin and Fidler, as it effectively removed them from office before their terms expired, contrary to Article VI, Section 7 of the Pennsylvania Constitution.The Supreme Court of Pennsylvania reviewed the case and focused on whether Section 402(e) was unconstitutionally applied. The Court held that Section 402(e) did not result in the removal of Martin and Fidler from office but rather modified their terms due to the reduction in the number of supervisors. The Court emphasized that Article VI, Section 7 of the Pennsylvania Constitution, which provides the exclusive method for removing elected officials, was not applicable because the statute did not involve removal but rather a lawful modification of legislative office terms.The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision, upholding the application of Section 402(e) and concluding that it did not violate the Pennsylvania Constitution. The Court found that the reduction in the number of supervisors and the subsequent election for the new three-member board were constitutionally permissible actions by the legislature. View "Martin v. Donegal Township" on Justia Law

Two electors, Faith Genser and Frank Matis, submitted mail-in ballots for the 2024 Primary Election without the required Secrecy Envelopes. The Butler County Board of Elections identified the defect and notified the electors that their mail-in ballots would not be counted. The electors then cast provisional ballots on Election Day. The Board did not count these provisional ballots, leading the electors to file a petition in the Court of Common Pleas of Butler County.The trial court dismissed the petition, upholding the Board's decision. It concluded that the Election Code did not support counting provisional ballots when a defective mail-in ballot had been submitted. The court emphasized that the Election Code's requirements for mail-in ballots were mandatory and that the Board's role was to ensure compliance with these requirements during canvassing.The Commonwealth Court reversed the trial court's decision, holding that the electors' provisional ballots should be counted. It found ambiguity in the Election Code's language regarding when a ballot is considered "cast" or "voted." The court interpreted the provisions to mean that a ballot must be valid and counted to preclude the counting of a provisional ballot. It concluded that the General Assembly intended to allow voters to remedy their circumstances when their initial mail-in ballot was invalid or incomplete.The Supreme Court of Pennsylvania affirmed the Commonwealth Court's decision. It held that the Election Code required the Board to count the electors' provisional ballots because their mail-in ballots were void due to the lack of Secrecy Envelopes. The Court emphasized that a void ballot has no legal effect and that the Election Code's provisions aim to prevent double voting while ensuring that every qualified voter has the opportunity to cast a vote. View "Genser v. Butler County Board of Elections" on Justia Law

In this case, the appellant, Cletus Rivera, was convicted of first-degree murder and sentenced to death for the killing of Reading Police Officer Scott Wertz. The incident occurred when Officers Wertz and Eddinger, working in plainclothes, responded to a disturbance and gunfire in a parking lot. Rivera, identified as the shooter, was pursued by Officer Wertz, who was subsequently shot and killed by Rivera. Rivera claimed self-defense, stating he did not know Wertz was a police officer. The jury convicted Rivera, and the death sentence was imposed based on aggravating circumstances, including the victim being a peace officer on duty.Rivera's conviction and sentence were affirmed by the Pennsylvania Supreme Court in 2009, and his petition for a writ of certiorari was denied by the U.S. Supreme Court in 2010. Rivera's first Post Conviction Relief Act (PCRA) petition was also denied, with the Pennsylvania Supreme Court finding no merit in his claims, including ineffective assistance of counsel and Brady violations related to a jailhouse informant, Jason Ott.In 2017, Rivera filed a second PCRA petition, citing newly discovered evidence from federal court proceedings that allegedly supported his previous claims about Ott's credibility and the existence of an undisclosed agreement between Ott and the Commonwealth. The PCRA court denied this petition, concluding that the new evidence was not material to Rivera's guilt or punishment and that his trial counsel's performance did not prejudice the outcome.The Pennsylvania Supreme Court, currently reviewing the case, vacated the PCRA court's order and remanded the case for further analysis. The Court directed the PCRA court to independently determine whether Rivera's claims met the newly discovered facts or governmental interference exceptions to the PCRA's time bar and whether they complied with the filing requirements. The Supreme Court emphasized that jurisdictional issues must be independently assessed, regardless of the parties' agreement on the timeliness of the petition. View "Commonwealth v. Rivera" on Justia Law

In August 2021, Michael Yard’s infant son died from blunt-force trauma to the head while Yard was the sole caregiver. The child had also suffered broken ribs weeks earlier. Yard was charged with first-degree murder and other offenses in April 2022 and was denied bail by a Magisterial District Judge. At a preliminary hearing, evidence including an autopsy report and a 911 call was presented, and all charges were bound over to the Monroe County Court of Common Pleas.Yard petitioned for bail, citing a Pennsylvania Supreme Court decision, Commonwealth v. Talley, which established a unique standard of proof for denying bail under the state Constitution. The bail court initially set bail at $200,000 with conditions but later vacated this decision, interpreting Talley to require live testimony rather than a "cold record." The Superior Court vacated the bail order and remanded for further proceedings. Yard then filed for nominal bail under Rule 600, which was granted by the bail court, setting bail at $1.00 with conditions.The Commonwealth appealed, and the Pennsylvania Supreme Court assumed jurisdiction. The Court held that the proof/presumption limitation in Article I, Section 14 of the Pennsylvania Constitution does not apply to the life-offense exception to the right to bail. Therefore, when a defendant is charged with an offense carrying a maximum sentence of life imprisonment, the Constitution categorically precludes release on bail. The Court vacated the bail court’s order granting nominal bail and remanded for further proceedings consistent with this opinion. View "Commonwealth v. Yard" on Justia Law

Circle of Seasons Charter School (Charter School) purchased two properties from The Pennsylvania State University (PSU) in May 2017. These properties were previously tax-exempt as part of PSU's Lehigh Valley Campus. Following the sale, Lehigh County issued assessment notices changing the properties' status from non-taxable to taxable, effective January 1, 2018. The notices did not include the required mailing date. Charter School claimed it did not receive these notices and subsequently did not pay the 2017 and 2018 tax bills until refinancing the properties in June 2018.The Lehigh County Court of Common Pleas sustained the preliminary objections of Northwestern Lehigh School District (School District) and dismissed Charter School's complaint with prejudice. The trial court found that Charter School had actual notice of the tax assessments by November 2017 and could have addressed the taxes in its 2018 annual appeal to the Lehigh County Board of Assessment Appeals (the Board). The Board granted tax-exempt status effective January 1, 2019, but Charter School did not seek retroactive relief or a refund for the taxes paid for 2017 and 2018.The Commonwealth Court reversed the trial court's decision, ruling that the defective notices entitled Charter School to a nunc pro tunc hearing before the Board to determine the validity of the assessment changes and potential refunds. The court emphasized that the omission of the mailing date on the notices was a significant defect, warranting a new hearing.The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision, reinstating the trial court's order. The Supreme Court held that Charter School had the burden to establish the properties' tax-exempt status and failed to do so in a timely manner. The court concluded that Charter School waived its claims by not seeking retroactive relief or a refund during the 2018 appeal and that nunc pro tunc relief was not warranted. View "Circle of Seasons Chart School v. Northwestern Lehigh School District" on Justia Law