Justia Pennsylvania Supreme Court Opinion Summaries

The case involves a facial constitutional challenge to Section 3755 of the Pennsylvania Vehicle Code, which authorizes warrantless blood draws from individuals requiring emergency medical treatment after a motor vehicle accident if there is probable cause to suspect DUI. Larry Wardell Hunte was involved in a serious car accident, and while unconscious at the hospital, a state trooper requested a blood draw under Section 3755, which revealed the presence of alcohol and controlled substances. Hunte was charged with multiple offenses, including homicide by vehicle while DUI.The Cumberland County Court of Common Pleas found Section 3755 unconstitutional, holding that it violated the Fourth Amendment and Article I, Section 8 of the Pennsylvania Constitution. The court reasoned that the statute authorized warrantless searches without any recognized exception to the warrant requirement, such as exigent circumstances or voluntary consent.The Supreme Court of Pennsylvania affirmed the lower court's decision. The court held that Section 3755 is facially unconstitutional because it mandates warrantless blood draws based solely on probable cause, without requiring a search warrant or demonstrating any exception to the warrant requirement. The court emphasized that the Fourth Amendment requires a warrant for such searches unless a valid exception applies, and statutory "implied consent" does not constitute such an exception. The court also rejected arguments that the statute could be applied constitutionally in certain circumstances, such as when a warrant is later obtained or exigent circumstances are present, noting that these scenarios do not involve actual applications of the statute. The court concluded that Section 3755 violates both the Fourth Amendment and the Pennsylvania Constitution. View "Commonwealth v. Hunte" on Justia Law

In 2012, George Thomas Shifflett was charged with driving under the influence (DUI) and accepted into an Accelerated Rehabilitative Disposition (ARD) program. In 2022, Shifflett was involved in another DUI incident and was charged as a second-time offender based on his previous ARD acceptance. Shifflett pled guilty to the 2022 DUI but contested the use of his 2012 ARD as a prior offense for sentencing purposes, arguing it was unconstitutional under Alleyne v. United States.The Adams County Court of Common Pleas granted Shifflett's motion to exclude evidence of his 2012 ARD and sentenced him as a first-time offender. The Commonwealth appealed, and the Superior Court vacated the sentence, remanding for resentencing as a second-time offender, citing recent Superior Court decisions that overruled Commonwealth v. Chichkin, which had held that using ARD as a prior offense for sentencing was unconstitutional.The Supreme Court of Pennsylvania reviewed the case to determine if considering Shifflett's ARD as a prior offense for sentencing violated Alleyne. The Court held that ARD does not equate to a conviction because it lacks the procedural safeguards of a criminal trial, such as the right to a jury trial and the requirement of proof beyond a reasonable doubt. Therefore, using ARD as a prior offense for sentencing enhancement is unconstitutional under Alleyne.The Court concluded that Section 3806 of the Motor Vehicle Code, which includes ARD in the definition of a prior offense, is facially unconstitutional to the extent it allows ARD to be used for sentencing enhancement. The Court reversed the Superior Court's order and remanded the case for reinstatement of Shifflett's original sentence as a first-time offender. View "Commonwealth v. Shifflett" on Justia Law

A group of appellants, including Firearms Owners Against Crime and two firearms dealers, filed a case against the Pennsylvania State Police (PSP) Commissioner, alleging that PSP was not complying with the Pennsylvania Uniform Firearms Act. The appellants claimed that PSP was intentionally understaffing its Pennsylvania Instant Check System (PICS) Operations Section, leading to significant delays in background checks for firearm purchases, sometimes exceeding seven hours. They argued that these delays violated the statutory requirement for "instantaneous" or "immediate" background checks and caused financial harm to firearms dealers due to canceled transactions.The Commonwealth Court initially issued a preliminary injunction, finding that PSP had a statutory duty to employ sufficient personnel to ensure compliance with the Act and that the delays were causing financial harm to the dealers. However, the court later sustained PSP's preliminary objections, ruling that the statute did not specify a mandatory timeframe for background checks and that the operational decisions regarding staffing were discretionary. The court also dismissed the appellants' request for a refund of the $2.00 background check fee, as the statute did not provide for such refunds.The Supreme Court of Pennsylvania reviewed the case and held that while the statute did not require "instantaneous" responses, it did mandate that PSP provide results as quickly as possible with available resources. The court affirmed the Commonwealth Court's denial of injunctive and mandamus relief, as these would compel affirmative action barred by sovereign immunity. However, the court reversed the denial of declaratory relief, allowing the appellants to seek a judicial declaration of PSP's duties under the Act. The court also vacated the order denying leave to amend the petition, allowing the appellants to include new allegations regarding PSP's response to the preliminary injunction. The case was remanded for further proceedings consistent with these findings. View "Firearms Owners v. Comm'r of PSP" on Justia Law

In March 2016, thirteen-year-old J.R. Gustafson was accidentally shot and killed by his fourteen-year-old friend at a residence in Mt. Pleasant, Pennsylvania. J.R.'s parents, Mark and Leah Gustafson, filed a lawsuit against Springfield Armory, the manufacturer of the firearm, and Saloom Department Store, the retailer that sold the firearm. They alleged defective design, negligent design and sale, and negligent warnings and marketing. The trial court dismissed the complaint with prejudice, citing the Protection of Lawful Commerce in Arms Act (PLCAA), which bars certain civil actions against firearms manufacturers and sellers.The Gustafsons appealed, and the Superior Court reversed the trial court's decision, remanding the case for further proceedings. The Superior Court's en banc panel issued a per curiam order, with no single rationale garnering majority support. Some judges found the PLCAA barred the claims but was unconstitutional, while others found the PLCAA did not bar the claims or was constitutional. The Superior Court's order was challenged, leading to the current appeal.The Supreme Court of Pennsylvania reviewed the case and determined that the PLCAA barred the Gustafsons' action. The court found that the action constituted a "qualified civil liability action" under the PLCAA, as it was a civil action against a manufacturer and seller of a qualified product for damages resulting from the criminal or unlawful misuse of a firearm. The court also concluded that the product liability exception did not apply because the discharge of the firearm was caused by a volitional act that constituted a criminal offense.The court further held that the PLCAA was a valid exercise of Congress's Commerce Clause authority and did not violate the Tenth Amendment or principles of federalism. Consequently, the Supreme Court of Pennsylvania vacated the Superior Court's order and remanded the case for reinstatement of the trial court's dismissal of the Gustafsons' complaint. View "Gustafson v. Springfield, Inc." on Justia Law

Prospect Crozer, LLC owned and developed 57.7 acres of real property in Upland Borough, Delaware County, assessed at $80,166,493 for tax years 2017-2019. Prospect appealed the assessment, but the Delaware County Board of Assessment Appeals denied it. Prospect then appealed to the Delaware County Court of Common Pleas, where the Chester Upland School District intervened. Senior Judge John L. Braxton, assigned by the Pennsylvania Supreme Court, presided over the de novo tax assessment proceedings. During this time, Judge Braxton was appointed to the Philadelphia Board of Revision of Taxes and received his first payment from the Board on June 16, 2019. He continued to preside over the tax appeals and issued orders in October 2019.The Delaware County Court of Common Pleas conducted a hearing to determine the timeline of Judge Braxton's dual service and found that he began receiving compensation from the Board on June 16, 2019. The Commonwealth Court then vacated the orders issued by Judge Braxton, concluding that his simultaneous service on the Board and as a judge violated Article V, Section 17(a) of the Pennsylvania Constitution, which prohibits judges from holding an office or position of profit in the government. The court held that this violation resulted in the automatic forfeiture of his judicial office, rendering the orders legal nullities.The Supreme Court of Pennsylvania reviewed the case and agreed that Judge Braxton violated Section 17(a) by holding a position of profit with a municipal corporation while serving as a judge. However, the court rejected the Commonwealth Court's conclusion that this violation resulted in the automatic forfeiture of his judicial office. Instead, the Supreme Court held that the violation created a constitutionally impermissible conflict of duties, requiring the vacatur of the orders entered in the tax appeals. The case was remanded to the Delaware County Court of Common Pleas for reassignment to a new judge. View "In re: Appeal of Prospect Crozer LLC From the Decision of the Board of Assessment Appeals of Delaware County, PA" on Justia Law

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