Justia Pennsylvania Supreme Court Opinion Summaries

Appellant Wayne Mitchell's petition for post-conviction relief was denied, and he appealed. Appellant admitted to and was convicted of the rape of his wife Robin in 1997. He was also charged with making terroristic threats, unlawful restraint, and simple assault. While appellant waited for his preliminary hearing, the wife filed for a Protection From Abuse order. Appellant waived the charges to court in exchange for a nominal bond, with a condition that he seek immediate in-patient treatment for alcohol abuse. However, for reasons disputed at trial, Appellant was never admitted to the hospital for treatment as required by the agreement, and instead confronted his wife where he later stabbed her to death, leaving her naked body in a lot close to her home. Appellant ultimately confessed to the killing, and later pled guilty to the earlier charges against him, in addition to his wife's murder. Upon review of appellant's petition for post-conviction relief, the Supreme Court found no reversible error in the PCRA court's denial of appellant's petition for relief. View "Pennsylvania v. Mitchell" on Justia Law

In September 1992, Michael Bardo was arrested for the death and indecent assault of his three-year-old niece. Finding unanimously that the aggravating factors outweighed the mitigating factors, the jury determined that Bardo should be sentenced to death. The trial court accordingly imposed the death sentence, and in 1998, the Pennsylvania Supreme Court affirmed the judgment of sentence on direct appeal. Bardo filed a timely PCRA petition. The Court was unanimous in affirming Docket No. 650 CAP, but was evenly divided on the appeal in Docket No. 651 CAP. Therefore, the grant of penalty phase relief was affirmed by operation of law. Part II of this opinion addressed Bardo's appeal of the PCRA court's order denying him guilt-phase relief (and several other penalty-phase claims). After careful review, the Court affirmed the denial of Bardo's guilt-phase claims for relief. View "Pennsylvania v. Bardo" on Justia Law

The Commonwealth appeals from the order granting a stay of execution, vacating appellee’s death sentence, and awarding a new penalty hearing under the Post Conviction Relief Act (PCRA). Appellee was sentenced to death after being convicted of the 1986 robbery and murder of Amos Norwood. This was appellee's second murder conviction. After review of the record, the Supreme Court concluded Appellee did not prove that a timeliness exception applied to the filing of his petition for relief, and that the PCRA court erred in finding Appellee established his burden of proof under the "governmental interference" exception. The Supreme Court vacated the stay of execution and the grant of a new penalty phase, and reinstate appellee's death sentence. View "Pennsylvania v. Williams" on Justia Law

The issue this case presented for the Supreme Court's review was whether the Superior Court erred in holding the right of a juvenile accused to be confronted with a witness against him conferred by the Confrontation Clause of the Sixth Amendment to the United States Constitution was violated where the juvenile court admitted into evidence an out-of-court, video-taped, forensic interview of a child complainant under the Tender Years Hearsay Act (“TYHA”), even though defense counsel did not cross-examine the child complainant who had taken the witness stand at the juvenile’s contested adjudication hearing. In light of the unique circumstances of this case (wherein the Commonwealth conceded continued questioning of the unconversable child complainant on direct examination would have been futile, and the juvenile court suggested she be removed from the witness stand), the Supreme Court held the admission of the recorded forensic interview of the child complainant violated the juvenile accused’s right to confrontation under the Sixth Amendment. Accordingly, the Court affirmed. View "In the Interest of: N.C." on Justia Law

Appellant, who had been inside the house, heard the officers enter, and fled through a third-story window, wearing only a pair of sweatpants and socks. He ran along a rooftop, jumped onto a car parked in an adjacent alley, and then ran to the home of Michele Gray. He informed Gray that he had beaten his girlfriend, Angelina Taylor, and that he had fled when he had heard the police in the house. He also told her that at the time he fled, Taylor had been pale, motionless, unresponsive, and having trouble breathing. Meanwhile, the officers made their way to the rear bedroom on the third floor, where they discovered a woman, later identified as Angelina Taylor, naked under a sheet on a mattress on the floor. Taylor was seriously injured, with numerous bruises and cuts visible on her face and body, including her pelvic region, as well as severe bruising on both sides of her throat and around both eyes. Officers called for emergency response personnel, who took the victim to the hospital. She was diagnosed as comatose due to bleeding in the brain. In the trauma unit, a rape-kit examination was conducted, which revealed numerous lacerations, bruises and abrasions. The victim never regained consciousness and her brainstem herniated from the swelling inside her head. Appellant was arrested, and a jury found Appellant guilty of first-degree murder and rape. The PCRA judge, who had also presided at trial, denied Appellant's petition for post-conviction relief, and Appellant appealed to the Supreme Court. Appellant raised twelve issues for review. Taking each and turn and finding Appellant did not meet his burden for relief, the Supreme Court affirmed the PCRA court's decision. View "Pennsylvania v. Davido" on Justia Law

Appellant was charged with a possessory weapons offense deriving from the use of a firearm in a broader criminal undertaking, although, factually, another person (Appellant’s brother) actually possessed the weapon during the episode and the defendant himself was unarmed. The weapon offense at issue, “[f]irearms not to be carried without a license,” pertained, inter alia, when an individual carries a concealed firearm on his person without a license. Such permutation, on its face did not apply to unarmed co-perpetrators in a larger criminal undertaking who simply were not “carr[ying] a firearm concealed on or about [their] person.” Nevertheless, the Superior Court’s opinion in this case was that the possessory weapons offense extended to persons who could have been accomplices in the abstract. The Supreme Court found that the Superior Court should have analyzed whether the evidence and reasonable inferences, taken in the light most favorable to the Commonwealth as the verdict winner, supported a conclusion that Appellant, acting with the intent to promote or facilitate his brother’s unlicensed carrying of a concealed firearm, solicited his brother to commit such offense or aided, agreed, or attempted to aid his brother in doing so. "In the absence of such a focused examination, the intermediate court’s broader assertion that, as accomplices, Appellant and his brother each were criminally liable for the other’s actions in the abstract is unsustainable." View "Pennsylvania v. Knox" on Justia Law

In 2009, C.B. (an adult male), along with his fiancee K.M.H (“the victim”) and her two daughters, J.H. (age 7) and A.H (age 4), and C.B.’s 11-year-old son J.B. were living together in a two-story rented house in a rural area surrounded by farmland and woods, and situated near the town of Wampum. K.M.H. was found dead with a single shotgun wound to the head shortly after C.B. had left for work for and J.H. and C.B. had left for school. K.M.H. was pregnant at the time of her death. The focus of the police investigation turned from K.M.H.'s ex-boyfriend to J.B., when police found that the ballistics of the shotgun pellets found in the victim matched that found on the shotgun seized from the residence. It was determined that J.B. had learned how to shoot this gun for hunting, and that the clothes J.B. wore to school the morning of the shooting had trace gunshot residue on them. The juvenile court issued written findings of fact adjudicating J.B. delinquent of criminal homicide for the death of K.M.H. and of her unborn child. J.B. filed a notice of appeal from the dispositional order, following which the juvenile court directed J.B. to prepare and file a statement of matters complained of on appeal. The juvenile court did not find J.B.’s weight of the evidence claim waived due to his failure to file a post-dispositional motion. Instead, the juvenile court ruled that J.B.’s weight of the evidence claim had been “adequately addressed . . . in its Findings of Fact and Conclusions of Law issued on April 13, 2012 and supplemental Opinion issued on April 20, 2012.” The Supreme Court found that J.B. faced procedural rules that made optional the filing of a post-dispositional motion, and which did not otherwise specify how a weight of the evidence claim was to be presented in the first instance to the juvenile court in order to preserve it for appellate review. Furthermore, J.B. presented his weight of the evidence claim to the lower court by raising it in his Pa.R.A.P. 1925(b) statement, in which he comprehensively set forth specific reasons why, in his view, the juvenile court’s adjudication was against the weight of the evidence. The Supreme Court concluded that a finding of J.B.’s weight of the evidence claim to be waived under the circumstances of this case would have been manifestly unjust. The Court remanded this case back to the juvenile court to allow J.B. to file a post-dispositional motion nunc pro tunc. View "In the Interest of J.B." on Justia Law

In this capital case, Appellant Arthur Bomar appealed the order of the Court of Common Pleas of Delaware County that denied his petition for relief under the Post Conviction Relief Act (“PCRA”). Appellant was subsequently charged with first-degree murder, rape, aggravated assault, kidnapping, and abuse of a corpse for the 1997 death of Aimee Willard. While Appellant’s appeal from resentencing was pending, counsel from the Federal Community Defender Office (“FCDO”) for the Eastern District of Pennsylvania Capital Habeas Unit filed on Appellant’s behalf a “Petition for Habeas Corpus Relief Pursuant to Article I, Section 14 of the Pennsylvania Constitution Statutory Post-Conviction Relief Under the Post-Conviction Relief Act [...],” which was deemed to be an amended PCRA petition. The PCRA proceedings were stayed pending the conclusion of Appellant’s direct appeal. The Superior Court affirmed Appellant’s judgment of sentence on the remaining offenses, and the Supreme Court denied allocatur. Nine months later, Appellant’s counsel filed a motion seeking an order declaring Appellant incompetent to proceed. Following a hearing on the matter and briefing by both parties, the PCRA court found Appellant competent and denied the motion. Thereafter, the Commonwealth filed a response to Appellant’s PCRA petition on March 31, 2008, and evidentiary hearings on appellant’s petition took place on July 17, 2007, May 28, 2008, November 5-7, 2008, January 15-16, 2009, April 28-29, 2009, September 24, 2009, October 20-21, 2009, February 1-3, 2010, July 28, 2010, November 29, 2011, January 20, 2011, and November 29, 2011. The PCRA court ultimately denied Appellant’s petition on March 28, 2012. Appellant filed a notice of appeal on April 23, 2012, and, on September 4, 2012, the PCRA court filed an extensive 213 page opinion addressing, and rejecting as meritless, each of the 22 claims in Appellant’s PCRA petition. Of those claims, he raised nine to the Supreme Court. Finding no reversible error as alleged in any of appellant's nine claims, the Supreme Court affirmed denial of PCRA relief. View "Pennsylvania v. Bomar" on Justia Law

Appellant Harold Winston Noel, Jr., was convicted of robbery and related offenses, and sentenced to an aggregate 29 to 58 years’ imprisonment for these crimes. In this discretionary appeal, he did not challenge the sufficiency of the evidence to sustain his convictions, but instead insisted that the trial court’s failure to conduct voir dire in strict compliance with Rule 631 of the Pennsylvania Rules of Criminal Procedure entitled him to a new trial. After careful consideration of appellant's argument on appeal and the prejudice it was alleged to have caused, the Supreme Court found no reversible error in the jury selection process employed by the trial court. View "Pennsylvania v. Noel" on Justia Law

The issue this Post Conviction Relief Act (“PCRA”) appeal presented for the Pennsylvania Supreme Court's review centered on a claim of ineffective assistance of counsel relative to counsel’s failure to seek suppression of an inculpatory post-polygraph statement made subsequent to a pre-polygraph counseled waiver defendant's Miranda rights. The PCRA court below denied relief. A divided Superior Court reversed and remanded in a 2-1 decision, in the process adopting and applying a test for measuring Miranda waivers devised by the U.S. Circuit Court of Appeals for the First Circuit after the trial in this matter. The panel majority held that: (1) appellee’s prepolygraph Miranda waiver did not encompass the post-polygraph interview; (2) the Commonwealth failed to prove that appellee validly waived his Sixth Amendment right to counsel for the post-polygraph interview; (3) appellee’s trial counsel lacked a reasonable basis for failing to seek suppression of the statement; and (4) the admission of the statement at trial was prejudicial. The Supreme Court granted certiorari because the Superior Court’s approach led to an underlying merits holding that presented an important issue of first impression. After review of this case, the Court held that the Superior Court’s approach was flawed in multiple respects, requiring a remand to that court to reconsider the ineffectiveness claim under the proper review paradigm. Accordingly, the Court vacated the order of the Superior Court and remanded for reconsideration of the issue. View "Pennsylvania v. Hill" on Justia Law