Justia Pennsylvania Supreme Court Opinion Summaries

On November 18, 2020, Officer Matthew Ibbotson and his partner stopped a silver Honda with heavily tinted windows in a high-crime area of Philadelphia for traffic violations. The driver, Omar Saunders, made suspicious movements, and Officer Ibbotson saw the handle of a gun under the driver’s seat. Saunders admitted he did not have a permit for the gun, which was later found to be stolen. Saunders was arrested, and the gun was seized.The Court of Common Pleas of Philadelphia County denied Saunders’s motion to suppress the gun, ruling that the seizure was justified under the plain view doctrine and the automobile exception, which requires both probable cause and exigent circumstances. Saunders was convicted of firearms offenses and sentenced to three and a half to seven years in prison. The Superior Court affirmed the judgment, holding that the seizure was lawful under the plain view doctrine.The Supreme Court of Pennsylvania reviewed the case to determine the legality of the warrantless seizure. The court held that the seizure was constitutional under the plain view doctrine. It found that the police had a lawful vantage point, the incriminating nature of the gun was immediately apparent, and the police had a lawful right of access to the gun. The court emphasized that the unexpected development of probable cause during a lawful traffic stop justified the seizure without a warrant. Consequently, the court affirmed the Superior Court’s order upholding the denial of suppression of the firearm. View "Commonwealth v. Saunders" on Justia Law

The case involves a group of appellants, including individual citizens, CeaseFirePA, and the City of Philadelphia, who challenged two Pennsylvania statutes that prevent local governments from enacting their own firearms regulations. The appellants argue that these statutes, Section 6120 of the Pennsylvania Uniform Firearms Act and Section 2962(g) of the Home Rule Charter and Optional Plans Law, hinder their ability to address gun violence effectively at the local level.The Commonwealth Court previously reviewed the case and dismissed the appellants' petition, sustaining preliminary objections for failure to state a claim. The court found that the appellants did not sufficiently allege violations of substantive due process under Article I, Section 1 of the Pennsylvania Constitution, the state-created danger doctrine, or improper interference with Philadelphia's delegated duties under the Local Health Administration Law and the Disease Prevention and Control Law of 1955.The Supreme Court of Pennsylvania reviewed the case and affirmed the Commonwealth Court's decision. The court held that the appellants failed to identify a constitutionally protected right that the statutes infringed upon, thus failing to establish a substantive due process claim. The court also concluded that the appellants did not meet the elements required to establish a state-created danger claim, particularly the requirement that the harm caused was foreseeable and fairly direct. Lastly, the court determined that the statutes did not interfere with Philadelphia's delegated public health responsibilities, as the relevant laws did not implicitly or explicitly authorize local firearm regulation.In summary, the Supreme Court of Pennsylvania affirmed the dismissal of the appellants' petition, upholding the statutes that preempt local firearm regulations. View "Crawford v. Commonwealth" on Justia Law

Alcatel-Lucent USA Inc. (Alcatel) challenged the constitutionality of Pennsylvania's 2014 cap on net-loss carryover (NLC) deductions for corporate net income (CNI) tax. The cap allowed corporations to carry forward net operating losses up to the greater of $4 million or 25% of the company's 2014 net income. Alcatel, with a net income of $27,332,333 and accumulated losses exceeding that amount, could only carry over $6,833,083 due to the cap, resulting in a taxable income of around $20 million and a tax liability of approximately $2 million. Alcatel paid the tax and sought a refund, arguing the cap violated the Uniformity Clause of the Pennsylvania Constitution.The Department of Revenue's Board of Appeals and the Board of Finance and Revenue denied Alcatel's refund request, citing lack of authority to decide constitutional issues. Alcatel then appealed to the Commonwealth Court, which initially affirmed the Board's decision, applying the Chevron test and concluding that the Nextel decision should not apply retroactively. However, after the Pennsylvania Supreme Court's decision in General Motors Corp. v. Commonwealth, which held that Nextel applies retroactively, an en banc panel of the Commonwealth Court reversed the earlier decision, sustaining Alcatel's exceptions and ordering a refund.The Supreme Court of Pennsylvania reviewed the case and concluded that the General Motors decision was erroneous. The Court held that Nextel should apply only prospectively, not retroactively, as it established a new principle of law. The Court applied the Chevron test, determining that retroactive application would not further the operation of the rule and would cause significant financial harm to the Commonwealth. Consequently, the Court reversed the Commonwealth Court's decision, ruling that due process does not require the Commonwealth to refund the taxes paid by Alcatel in 2014. View "Alcatel-Lucent USA Inc. v. Commonwealth" on Justia Law

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