Justia Pennsylvania Supreme Court Opinion Summaries

The issue the Supreme Court addressed in these consolidated appeals centered on the extent of the public’s statutory right of access to discrete information about the implementation of the Medical Assistance Program. In 2011, James Eiseman, Jr. and the Public Interest Law Center of Philadelphia (“Requesters”) tendered requests to the Department of Public Welfare (DPW) seeking records revealing, among other things, the rates that DPW paid to managed care organizations (MCOs) for dental services in the Southeast Zone (the “Capitation Rates”), and the amounts paid by MCOs to provide dental services (the “MCO Rates”). These were submitted per the Right-to-Know Law (RTKL). DPW denied the requests. Pertinent to the Supreme Court’s review of this case, with regard to the MCO Rates, the Department indicated that it had been informed by each of the MCOs that the rates were “trade secrets and/or confidential proprietary information” protected against disclosure. The Department did not deny that it possessed pertinent records; rather, it related that the MCOs had instructed that “DPW is not to disclose” the rates. The Office of Open Records (OOR), however, issued a final determination granting the relevant records requests. Initially, an appeals officer observed that records in the possession of a Commonwealth agency were presumed to be public, unless they qualified for an exemption under the RTKL or other law or are protected by a privilege, judicial order, or decree. In a divided opinion, the Commonwealth Court sustained the portion of the OOR’s determination concerning Capitation Rates, as the members of an en banc panel unanimously agreed that contracts between DPW and the MCOs were financial records under the Law. In the absence of a legislative evaluation, the Supreme Court could not conclude that records which must be submitted to a government agency for approval, were not records “dealing with” the agency’s monetary disbursements and services acquisitions. "[I]f the General Assembly wished for dissemination to be withheld, it would have been a straightforward matter to provide for redaction of trade-secrets information in Section 708(c) of the Law, as was done in relation to eight of the other openness exceptions which are otherwise withheld from financial records." The Court focused upon the conclusion that records which were required to be submitted to and approved by DPW, and which reflected the central means of implementing a core departmental function, were records “dealing with” DPW’s disbursement of public monies and its responsibility to afford access to healthcare services in furtherance of the public interest. The order of the Commonwealth Court holding to the contrary was reversed relative to the MCO Rates, and the matter was remanded for further proceedings. View "Dept. of Public Welfare v. Eiseman" on Justia Law

A jury convicted appellant George Hitcho, Jr. of first degree murder for the death of Freemansburg Police Officer Robert Lasso in 2011. At the penalty phase, the jury found one aggravating circumstance and three mitigating circumstances, unanimously determined the aggravating circumstance outweighed the mitigating circumstances, and sentenced appellant to death. Upon review of the trial court record, the Supreme Court found "no basis upon which to upset the death verdict," and affirmed appellant's conviction and sentence. View "Pennsylvania v. Hitcho" on Justia Law

In 2007, Terra Technical Services, LLC subcontracted with River Station Development which in turn entered into a written contract with River Station Land, L.P., the terms of which provided that Terra Technical would perform demolition and debris removal of structures of various types and sizes on a seventy-six acre parcel of land owned by River Station for an agreed upon amount. In 2009, Terra Technical provided formal notice to River Station of its intention to file a mechanics’ lien claim pursuant to 49 P.S. 1501.In 2010, Terra Technical filed seventeen identical mechanics lien against River Station's designated parcels of land, including the buildings and structures thereon, wherein it alleged it had begun the demolition work on the property on July 31, 2007, and completed its contractual duties on December 23, 2008, although it did not receive the full amount of the agreed upon price for its services. Although River Station filed preliminary objections to Terra Technical’s mechanics’ lien claims on January 5, 2011, and Terra Technical filed responses thereto on January 25, 2011, the trial court did not issue a ruling thereon in light of the failure of either party to take the action necessary to bring the preliminary objections before the trial court. In 2012, Terra Technical filed seventeen complaints to obtain judgment on the corresponding mechanics’ lien claims. In this appeal the question this case raised for the Supreme Court's review centered on whether the Mechanics’ Lien Law required a claimant filing a complaint to enforce a previously filed mechanics’ lien claim to docket such complaint under a term and number separate from that which had been assigned to the mechanics’ lien claim itself. The Supreme Court held that it did not, and accordingly, reversed. View "Terra Technical Services v. River Station Land, L.P." on Justia Law

On the night of March 9, 2001, appellant Stephen Treiber set fire to his home while his girlfriend, Denise Riddle, and his two-year-old daughter, Jessica, slept inside. As the home burned, appellant and Riddle escaped, but Jessica remained in her crib until firefighters removed her; however, they were unable to revive her. Appellant was charged with criminal homicide, reckless endangerment, and multiple counts of arson. Appellant appealed the denial of collateral relief to his criminal convictions and death sentence pursuant to the Post Conviction Relief Act (PCRA). Upon careful consideration of appellant's arguments on appeal and the trial court record, the Supreme Court held that the PCRA court's conclusions were "free from legal error" and supported by the record. Therefore, appellant was not entitled to relief. View "Pennsylvania v. Treiber" on Justia Law

Appellant Collette Brown, a resident of Concord Township, Delaware County, appealed the Commonwealth Court's order affirming the trial court's dismissal of her petition to place on the November 2014 ballot, a referendum question seeking to change the Township's governmental status from second-class to first-class. Appellant's petition contained 994 signatures (8.5%) out of the Township’s 11,640 registered voters and claimed that as of the 2010 census, the Township had a population density of around 1,258 inhabitants per square mile (“IPSM”). As stated, both figures easily exceeded the statutory thresholds of 300 IPSM and 5% registered voter signatures, which Appellant believed operated as conjunctive preconditions. Seven named qualified electors (“Appellees”) filed objections and claimed the petition was substantively and procedurally defective under Pennsylvania law, which they argued was time-limited to the first municipal or general election occurring at least ninety days after the 2010 census. That same day, the Delaware County Bureau of Elections intervened and requested declaratory relief, claiming that in addition to not satisfying the statutory requirements, the petition should have been dismissed because a home rule study referendum question was already on the ballot (which voters later approved), and that if Appellant’s referendum question were successful, the subsequent change in Township government could violate the Pennsylvania Constitution. Upon review, the Supreme Court concluded that pursuant to 53 P.S. section 55207, second- to first-class township referendum questions shall be submitted to voters at the first general or municipal election occurring at least ninety days after fulfilling both the population density ascertainment and petition signature filing requirements as set forth in the statute. Accordingly, the Court reversed the order of the Commonwealth Court and remanded the case to the trial court for further proceedings. View "In re: Ballot Quest to Concord Twp" on Justia Law

Appellant Shonda Walter was convicted for the 2003 first-degree murder of James Sementelli, for which she received the death penalty. Appellant timely filed a PCRA petition, raising a claim that her appellate attorney had rendered ineffective assistance of counsel in failing to develop the arguments in her brief, as well as numerous other claims. Upon the Commonwealth and Appellant’s consent, the PCRA court granted relief, reinstating Appellant’s right to file a direct appeal nunc pro tunc of the judgment of sentence of death, and thus declined to reach her other claims. Appellant timely appealed to the Supreme Court, raising ten issues, and, after an initial round of briefing, the Court entered an order noting that the trial court had not prepared an opinion in support of its decision to grant Appellant a new direct appeal nunc pro tunc or an opinion concerning Appellant’s issues on appeal, and directing it to do so. After the opinion was prepared, and the Supreme Court reviewed it, the Supreme Court found no reversible error in the lower courts' decisions, and affirmed appellant's conviction and death sentence. View "Pennsylvania v. Walter" on Justia Law

Appellant Richard Laird was convicted for the 1987 killing of Anthony Milano. Appellant and a co-defendant were tried together in May 1988. Each testified and admitted he was present at the crime scene, but blamed the other for the killing. Both defendants were convicted of first-degree murder, kidnapping, aggravated assault, and related offenses. Both were sentenced to death. The Pennsylvania Supreme Court affirmed the sentences. Appellant was unsuccessful in his state application for post-conviction relief; the federal district court granted in part his petition for habeas relief, vacating the first-degree murder conviction and death sentence. With the kidnapping conviction still in place, the Commonwealth retried appellant on the first-degree murder charge in 2007. The jury convicted appellant of first-degree murder, and he was again sentenced to death. Appellant filed an amended PCRA petition, raising thirteen claims. The PCRA court dismissed two claims without a hearing; the remainder were dismissed after a hearing in which a number of witnesses testified. Appellant appealed the PCRA's dismissal of his claims, principally arguing he received ineffective assistance of trial counsel, and the cumulative effect of counsel's alleged errors were grounds for relief. Finding no reversible error, the Supreme Court affirmed appellant's conviction and death sentence. View "Pennsylvania v. Laird" on Justia Law

Appellant Andre Staton was convicted in 2006 for the first degree murder of his girlfriend, for which he received the death sentence. The sentence was affirmed on direct appeal, and he applied for collateral relief pursuant to the Post Conviction Relief Act (PCRA). The PCRA court denied the petition without a hearing, and appellant appealed that denial to the Supreme Court. Because the Supreme Court concluded the PCRA court's findings were supported by the record and that there were no reversible errors in that court's conclusions, the denial of post-conviction relief was affirmed. View "Pennsylvania v. Staton" on Justia Law

In this capital case, the United States District Court for the Western District of Pennsylvania held that Appellant Scott Wayne Blystone was entitled to receive a new sentencing hearing after concluding that his counsel was ineffective for failing to investigate and develop penalty-phase mitigating evidence in the form of institutional records and expert mental-health evidence. The United States Court of Appeals for the Third Circuit affirmed, and Appellant the new penalty-phase hearing was pending following the completion of discovery. Throughout the course of counsel’s current mitigation investigation, Appellant’s mother, Norma Blystone, refused to divulge certain "critical" information regarding Appellant’s childhood unless she was assured that the information she provided would not be made public. In an attempt to provide Mrs. Blystone with such assurances and to obtain this additional information from her, Appellant filed a motion for limited courtroom closure and temporary sealing of transcripts with respect to Mrs. Blystone’s testimony, any expert testimony addressing the information Mrs. Blystone might reveal, and any closing arguments referencing such testimony. The trial court denied the motion, and Appellant filed an interlocutory appeal. After review, the Supreme Court concluded that it lacked jurisdiction to review the trial court’s interlocutory order denying Appellant’s closure motion, and, accordingly, this appeal was quashed. View "Pennsylvania v. Blystone" on Justia Law

The Commonwealth appealed the Philadelphia Court of Common Pleas' granting of appellee Edward Bracey’s Post Conviction Relief Act (PCRA) petition. The court determined appellee suffered from an intellectual disability, and vacated his death sentence. After review of the specific facts of this case, the Pennsylvania Supreme Court found no reversible error in that decision, and affirmed. View "Pennsylvania v. Bracey" on Justia Law