Justia Pennsylvania Supreme Court Opinion Summaries

Appellants, twenty-four Pennsylvania voters, filed this action in 2006 in the Commonwealth Court's original jurisdiction to challenge the certification of six direct-recording electronic voting systems (DREs) models in use in Pennsylvania. Seeking declaratory, mandamus, and injunctive relief, Appellants claimed the Secretary of the Commonwealth should have been ordered to decertify the DREs which did not comply with the Election Code and compelled to adopt more rigorous testing standards. In this appeal, the issue presented for the Supreme Court's review centered on whether the Commonwealth Court erred in upholding the decision of the Secretary to certify certain DREs for use in Pennsylvania elections. The Commonwealth Court found that the DREs satisfied the certification requirements set forth in the Election Code and did not infringe on the fundamental right to vote as protected by the Pennsylvania Constitution. The Supreme Court concluded that the Commonwealth Court did not err in granting the Secretary's petition for summary relief. In particular, the Court found the Secretary exercised proper discretion in determining that the certified DREs satisfied the requirements for electronic voting systems set forth in the Election Code and the use of the DREs did not violate Appellants' fundamental right to vote as embodied within Article I, Section 5 of the Pennsylvania Constitution or the uniformity requirement in Article VII, Section 6 of the Pennsylvania Constitution. View "Banfield v. Sec'y of Commonwealth" on Justia Law

In this capital case, Herbert Blakeney, a.k.a. Shabazz Muhammad, appealed a Court of Common Pleas order that denied his petition for relief under the Post Conviction Relief Act (“PCRA”) without a hearing. Blakeney was convicted for the stabbing deaths of his wife and her 14-month old son in the early morning hours of February 2, 2000. After careful consideration of Blakeney's arguments on appeal, the Supreme Court found that the PCRA court properly dismissed his petition for post-conviction relief without a hearing. View "Pennsylvania v. Blakeney" on Justia Law

Appellant Gerald Watkins appealed the denial of his petition for post-conviction relief, which was filed after the Supreme Court’s affirmed his direct appeal from three death sentences imposed following his conviction for murdering his girlfriend, their newborn daughter, and his girlfriend’s son. Finding that the PCRA court did not err in denying appellant relief, the Supreme Court affirmed that court's decision. View "Pennsylvania v. Watkins" on Justia Law

Eight years after the charges against him were dismissed, appellee Todd Allen petitioned to have the property seized from the vehicle he was driving at the time of his arrest returned to him. The trial court concluded appellee's claim was waived because it had not been raised before the trial court that had jurisdiction over his criminal case. The Commonwealth Court applied a six-year statute of limitations, declining to follow the authority relied upon by the trial court ("Pennsylvania v. Setzer, 392 A.2d 772 (Pa.Super 1978)), and found appellee's motion was therefore untimely. The Commonwealth appealed the Commonwealth Court's judgment, and the Supreme Court was persuaded that the Commonwealth Court erred by applying the statute of limitations analysis. The Supreme Court concluded the trial court was correct in its analysis: because appellee had a prior opportunity to move for the return of the property in the pendency of criminal charges against him, failing to do so waived the issue. View "Pennsylvania v. Allen" on Justia Law

In a discretionary appeal, the issue this case presented for the Supreme Court's review centered on whether the Superior Court erred in making certain legal determinations leading it to vacate the judgment of sentence imposed upon Appellee Tyde Pasture following the revocation of his probation. Pasture sexually molested his live-in paramour’s daughter, beginning when she was nine years of age. Upon review, the Supreme Court concluded the Superior Court misapplied certain sentencing provisions, leading it to give insufficient deference to the revocation court’s imposition of the sentence following the revocation of Pasture’s probation. The Supreme Court vacated the Superior Court’s order and reinstated Pasture’s original judgment of sentence. View "Pennsylvania v. Pasture" on Justia Law

Appellant Christopher Johnson appealed the sentence of death he received for first-degree murder and related charges in the 2010 shooting death of Officer David Grove. Grove was patrolling an area near Gettysburg National Military Park when he saw appellant's car stopped near the Battlefield. Grove was later discovered by a fellow officer, shot three times, including a fatal shot to the back of the neck. Appellant raised multiple issues on appeal to the Supreme Court, but finding no reversible error, and that the evidence sufficiently supported the sentence, the Supreme Court affirmed appellant's sentence of death. View "Pennsylvania v. Johnson" on Justia Law

In 2012, the Commonwealth filed a criminal complaint against appellee Jason Hoover alleging he and two co-conspirators, Barry Martell and D.M. (a juvenile), stole parts and equipment from RES Coal Company and later sold the stolen parts to a local salvage yard. The Commonwealth appealed Superior Court Order vacating appellee’s judgment of sentence for theft by unlawful taking, receiving stolen property, criminal conspiracy, and corruption of minors, and remanding for a new trial. The Superior Court concluded that the trial court abused its discretion in determining that the probative value of appellee’s prior crime of dishonesty substantially outweighed its prejudicial effect. The Supreme Court reversed and remanded: "[t]here was no need, or warrant, for the Superior Court to seek to innovate a novel standard for admitting a prior conviction for impeachment purposes, particularly one based on federal sources, since the applicable Pennsylvania Rule of Evidence and the corresponding federal rule, F.R.E. Rule 609, are quite distinct. Thus, while subsection (d)(2) of the corresponding federal rule limits the admissibility of juvenile adjudications to those of witnesses other than the defendant, subsection (d) of the Pennsylvania rule, as stated, contains no such limitation, but specifically allows the use of juvenile adjudications for impeachment purposes. Thus under Pennsylvania law, prior adult convictions of crimes of dishonesty remain fair game for impeachment in appropriate circumstances. The case was remanded for the Superior Court to consider appellee’s remaining claim regarding appellee’s proposed alibi testimony. View "Pennsylvania v. Hoover" on Justia Law

In 2008, a jury convicted Appellant Cletus Rivera of the first degree murder of Police Officer Scott Wertz. Appellant was sentenced to death, and the Pennsylvania Supreme Court affirmed his judgment of sentence. After affording Appellant notice of its intent to dismiss his PCRA petition without conducting an evidentiary hearing, the PCRA court dismissed Appellant’s petition, holding there were no genuine issues of material fact and no meritorious issues. Appellant appealed that decision to the Supreme Court. Finding no reversible error, the Supreme Court affirmed. View "Pennsylvania v. Rivera" on Justia Law

Appellee Andrew Enimpah was a passenger in a car stopped by police; he was asked to step out of the vehicle, and when he did, a plastic bag fell from his lap. The driver consented to a search of the car and police seized the bag, which contained cocaine. All occupants denied knowledge of the bag, but appellee was charged. He moved to suppress, challenging the constitutionality of the detention that led to the search. At the suppression hearing, the prosecutor refused to offer evidence until appellee met the "threshold" of appellee offering proof of his reasonable expectation of privacy in the area where the plastic bag was found. After much debate, the trial court informed the prosecutor it would be obliged to grant the motion if she failed to present any evidence. The prosecutor maintained her position, stating, “If I’m wrong[,] the [a]ppellate courts will tell me that[;] then I will respect that decision.” The trial court suppressed the evidence; the Superior Court affirmed. The Supreme Court affirmed that decision and reiterated that which should be clear: "In all cases, the burden of production is [] upon the Commonwealth." View "Pennsylvania v. Enimpah" on Justia Law

The issue this case presented for the Supreme Court's review centered on the constitutionality of provisions of the Sex Offender Registration and Notification Act (SORNA) as applied to juveniles. An order of the York County Court of Common Pleas held the statute unconstitutional as violative of the ex post facto clause, protections against cruel and unusual punishment, and due process rights through the use of an irrebuttable presumption. The seven juveniles in this case were previously adjudicated delinquent in regard to specific sexual crimes and were subject to juvenile court supervision on SORNA’s effective date. Accordingly, the Juveniles became subject to lifetime registration under 42 Pa.C.S. 9799.15(a)(4). The Juveniles filed motions for nunc pro tunc relief asserting SORNA’s unconstitutionality, which were consolidated by the trial court, following the passage of SORNA and its attachment to them. After review, the Supreme Court affirmed the determination that SORNA violated juvenile offenders’ due process rights through the use of an irrebuttable presumption. View "Interest of: J.B." on Justia Law