Justia Pennsylvania Supreme Court Opinion Summaries

In 2009, two girls were sexually assaulted. Sixteen-year-old C.J. escaped, but eleven-year-old N.O. was threatened and lured into an alleyway, where she was brutally raped and sustained severe injuries requiring hospitalization and surgery. Police investigated and arrested Appellee Jose Carrasquillo, who made inculpatory statements during interrogation. Charges were lodged in two separate criminal proceedings, which were later consolidated for trial. Appellee decided to enter open guilty pleas to various sexual offenses, including rape, as well as other crimes. At the plea colloquy, the Commonwealth proffered that the evidence against Appellee that included his own statements, identification testimony from both victims, video surveillance recordings apparently showing Appellee with or in the vicinity of each victim close in time to the assaults, and DNA and fingerprint evidence linking Appellee to the rape of N.O. The plea court advised Appellee of his pertinent constitutional rights and the implications of waiver. The plea court accepted appellee's pleas and entered verdicts. Appellee was also informed that he could seek to withdraw his guilty plea at any time before sentencing and that the court "would have to consider whether or not the reasons for you doing so are fair and necessary, fair and appropriate, compared to the prejudice that that might cause to the Commonwealth's case and to their witnesses, and particularly in this case to child witnesses." Three and a half months later, the court conducted a sentencing hearing. After the defense rested, Appellee explained in allocution that he had pled guilty to spare N.O. suffering, and he therefore expressed surprise at his portrayal during the sentencing hearing. Appellee also stated that he had entered his plea because, absent a polygraph examination, his account would not have been believed and he would not have received a fair trial. In this appeal, the issue this case presented for the Supreme Court's review centered on the criteria governing the disposition of a presentence motion to withdraw a guilty plea. The Court's decision turned on the conclusion that a bare assertion of innocence was not, in and of itself, a sufficient reason to require a court to grant such a request. The Court was persuaded by the approach of other jurisdictions: "the proper inquiry on consideration of such a withdrawal motion is whether the accused has made some colorable demonstration, under the circumstances, such that permitting withdrawal of the plea would promote fairness and justice. The policy of liberality remains extant but has its limits, consistent with the affordance of a degree of discretion to the common pleas courts. This case, in our view, illustrates why the existing per se approach to innocence claims is unsatisfactory." In this case, the Supreme Court found that the trial court acted within its discretion to refuse the attempted withdrawal of the plea. View "Pennsylvania v. Carrasquillo" on Justia Law

This appeal was a companion case with "Pennsylvania v. Carrasquillo." The issue presented centered on whether a common pleas court was required to permit withdrawal of a guilty plea, upon the defendant-appellee's assertion of innocence. Appellee stabbed his estranged wife, Kimberly, to death. He immediately surrendered to police and confessed. Subsequently, he pled guilty to first-degree murder and possession of an instrument of crime. In exchange for the plea, the Commonwealth was to recommend that Appellee would receive the mandatory sentence of life imprisonment for first-degree murder and a consecutive term of incarceration pertaining to the possessory offense. Just over two months later, when Appellee appeared for sentencing, he advised the court that he wished to withdraw his plea. In "Carrasquillo," the Pennsylvania Supreme Court determined that a bare assertion of innocence (such as Appellee provided as the basis for withdrawing his guilty plea) was not, in and of itself, a sufficient reason to require a court to grant such a request. Accordingly, and for the reasons set forth more fully in that case, the common pleas court did not err in denying Appellee's withdrawal motion. View "Pennsylvania v. Hvizda" on Justia Law

The Pennsylvania Supreme Court granted review to consider whether appellant was subject to custodial interrogation during an encounter with parole agents, such that their failure to issue Miranda1 warnings violated his Fifth Amendment rights. The Superior Court held that Miranda warnings were not required during questioning by the parole agents because appellant's statements were merely part of a parole interview rather than a custodial interrogation. It noted custody was equivalent to "a formal arrest or restraint on freedom of movement of the degree associated with a formal arrest." The court reviewed various factors and found the mere fact appellant was handcuffed was insufficient to show he was arrested. Appellant argued to the Supreme Court that the parole agent should have issue Miranda warnings to a parolee when he was in custody and questioned about new crimes. Under the facts of this case, the Supreme Court agreed that appellant was subject to custodial interrogation such that his parole agents' failure to issue Miranda warnings violated his Fifth Amendment rights, and the courts below erred in failing to suppress his incriminating statements, and such error was not harmless. Thus, appellant was entitled to a new trial consistent with the guidelines the Court set out in this opinion. View "Pennsylvania v. Cooley, III" on Justia Law

The issue this case presented for the Supreme Court's review centered on the constitutionality and severability of 18 Pa.C.S. section 6317(a), which imposed a mandatory minimum sentence of two years total confinement upon a defendant for a conviction if a delivery or possession with intent to deliver a controlled substance occurs within 1,000 feet of, inter alia, a school in light of the United States Supreme Court's decision in "Alleyne v. United States," (133 S. Ct. 2151 (2013)). In 2013, the Pennsylvania State Police filed a criminal complaint against Appellee Kyle Hopkins, charging him with various violations of the Controlled Substance, Drug, Device and Cosmetic Act. The charges arose from three incidents which took place over three days in April 2012, during which Appellee sold heroin to a confidential informant in Kennett Square Borough and New Garden Township, Chester County. One sale allegedly occurred in a school zone. Appellee was held for court on all charges stemming from those instances, in all, Appellee had 12 counts against him. The trial court reasoned that it was bound by the United States Supreme Court's decision in "Alleyne," and granted Appellee's Motion for Extraordinary Relief. The Commonwealth appealed. After review, the Pennsylvania Supreme Court affirmed, holding that numerous provisions of Section 6317 were "constitutionally infirm" under Alleyne. Moreover, the remaining provisions of Section 6317, standing alone, were incomplete and "incapable of being vindicated in accord with the intent of the General Assembly." Because of the significant provisions found to violate the Constitution and the remaining unoffending provisions of Section 6317 were incapable of being severed. The Court declined to "rewrite Section 6317 or create a substantive offense which the General Assembly clearly did not desire." View "Pennsylvania v. Hopkins" on Justia Law

This appeal centered on the nature of a valid invocation of the Miranda-based right to counsel, specifically, in terms of whether the right must be asserted in close temporal proximity to custodial interrogation or may be effectively invoked remotely from such questioning. Appellee Dennis Bland, Jr. allegedly shot and killed Keron Remberan in Philadelphia, then fled to his mother’s house in Florida. After learning of Appellee’s whereabouts, police obtained an arrest warrant and notified Florida law enforcement. Federal authorities in Florida detained Appellee, who was seventeen years old at the time, and he was placed in a juvenile facility to await extradition to Pennsylvania. The day after Appellee’s arrest, his father contacted the Defender Association of Philadelphia and apprised an attorney of his son’s circumstances. The lawyer sent a form letter via facsimile to Florida counsel representing Appellee in connection with the extradition proceedings, asking that Appellee sign and return the document. The letter reflected a very clear putative invocation of the Miranda-based right to counsel. Six days after Appellee had signed the form sent by the Defender Association while he was in Florida, a detective provided him with Miranda warnings. During ensuing questioning, Appellee ultimately confessed to perpetration of the killing, and, after later consultation with his father, he also provided a written confession. Appellee was charged with murder, firearms violations, and several related offenses, and the Defender Association was formally appointed as counsel. Appellee filed a pre-trial motion to suppress his written statement, claiming that police violated his rights under Miranda, as well as under Article 1, Section 9 of the Pennsylvania Constitution. The Supreme Court held that, to require a suspension of questioning by law enforcement officials on pain of an exclusionary remedy, an invocation of the Miranda-based right to counsel must be made upon or after actual or imminent commencement of in-custody interrogation. View "Pennsylvania v. Bland" on Justia Law

Following a jury trial on charges that he endangered the welfare of children, appellee William Lynn was convicted and sentenced to a term of three to six years of incarceration. On appeal, he challenged the sufficiency of the evidence, arguing that he had no direct supervision of the children he was found to have endangered. The Superior Court agreed, and reversed his conviction. On the Commonwealth’s appeal, the Supreme Court reversed the Superior Court, concluding that there was no statutory requirement of direct supervision of children. "Rather, that which is supervised is the child’s welfare. Under the facts presented at trial, Appellee was a person supervising the welfare of many children because, as a high-ranking official in the Archdiocese of Philadelphia, he was specifically responsible for protecting children from sexually abusive priests." View "Pennsylvania v. Lynn" on Justia Law

Appellant Noel Montalvo was the brother of Milton Montalvo. Milton was convicted of the 1999 murder his common-law wife Miriam Ascensio. Appellant would later be charged as being an accomplice to the murder. More than three years after Milton was convicted of two counts of first-degree murder for the deaths of Miriam and Nelson, a jury convicted Appellant of first-degree murder for the death of Miriam, second-degree murder for the death of a friend of Miriam's, Nelson Lugo, conspiracy to commit murder, and burglary. Appellant applied for post-conviction relief, listing eleven alleged errors at trial that ultimately entitled him to relief. "As a result of the PCRA court’s failures, [the Pennsylvania Supreme] Court has no findings of fact, no determinations of credibility, and no legal conclusions regarding Appellant’s PCRA claims; in short, [the Court had] no basis upon which to conduct meaningful appellate review." The Court vacated the PCRA court's judgment, and remanded the case for further proceedings. View "Pennsylvania v. Montalvo" on Justia Law

In July 2012, claimant Charles Chamberlain was unemployed and was receiving unemployment compensation benefits. In October, he pled guilty to the summary offenses of operating a vehicle without a valid inspection, and driving with a suspended license. Relating to the latter conviction, Claimant was sentenced to sixty days in the Keystone House Arrest Program (from November 1, 2012 to December 31, 2012) with the condition that if he failed to comply, he would serve sixty days in the York County Prison. Claimant was also required to attend reemployment eligibility assessment classes. The terms of Claimant’s house arrest restricted him to the home of his sister, but permitted him to work, run errands, and do his Christmas shopping. On November 28, 2012, the local service center of the Office of Unemployment Compensation Benefits issued a notice of determination that Claimant’s sentence of house arrest disqualified him from receipt of benefits because he was “incarcerated after a conviction” under Section 402.6. Claimant appealed the finding of disqualification and, in 2013, a hearing was held before a referee for the Unemployment Compensation Board of Review (UCBR). The referee concluded Claimant was disqualified from receiving benefits, and Claimant appealed. Mindful of the remedial purpose of the Unemployment Compensation (UC) Law, the Commonwealth Court held that a claimant sentenced to house arrest is not “incarcerated” under Section 402.6. Because the terms and conditions of the claimant’s house arrest did not otherwise prevent him from satisfying the statutory requirements for obtaining unemployment compensation benefits, the Commonwealth Court reversed the denial of benefits. Agreeing with the Commonwealth Court's conclusion, the Supreme Court affirmed. View "Chamberlain v. Unemployment Compensation Review Bd." on Justia Law

The Post Conviction Relief Act (PCRA) court, after a hearing, rendered an opinion in which it resolved several issues on remand from the Supreme Court. Pertinent to this appeal, the issue was whether appellant received ineffective assistance of trial counsel, and was therefore entitled to relief. With the remand proceedings complete, the Supreme Court considered the issue of whether appellant was entitled to relief based on the cumulative prejudicial effect of all of the alleged errors he set forth in his petition. The Court held that the PCRA court properly resolved the ineffectiveness claims before it, and the Supreme Court concluded that appellant was not entitled to relief on his claim of cumulative prejudice. Thus, the Court affirmed the order of the PCRA court and dismissed all of appellant's claims. View "Pennsylvania v. Simpson" on Justia Law

After state police seized over two and one-half pounds of marijuana from appellee Dreama Stotelmyer's residence pursuant to a search warrant, she was charged with possession of a controlled substance with intent to deliver (PWID) and possession of drug paraphernalia. Appellee entered an open guilty plea to PWID, and the Commonwealth nolle prossed the remaining charge. After entry of the plea, the Commonwealth entered notice of its intent to seek application of the mandatory minimum one-year sentence of incarceration. After a hearing, the trial court determined the Commonwealth proved by a preponderance of the evidence that appellee possessed over two pounds of marijuana with the intent to distribute it, invoking 18 Pa.C.S. 7508's mandatory minimum sentencing provisions. However, the trial court instead sentenced appellee to county intermediate punishment, imposing six months of work release from the county jail followed by six months of electronic home monitoring. Following the denial (by operation of law) of its motion to modify sentence, the Commonwealth appealed to the Superior Court, and then to the Supreme Court. The Supreme Court, after review, concluded the Superior Court erred in holding that appellee was eligible for the intermediate punishment sentence when the mandatory minimum sentence under 18 Pa.C.S. 7508 applied. View "Pennsylvania. v. Stotelmyer" on Justia Law