Justia Pennsylvania Supreme Court Opinion Summaries

The Commonwealth appealed the reversal of appellee Willie Brooks' sentence and grant of a new trial. Appellee was appointed defense counsel after being charged with criminal attempt to commit homicide, possession of a firearm, possession of an instrument of crime, and loitering and prowling at night. After a pre-trial conference was continued six times, trial was set nearly two and a half years after appellee was originally charged. The day jury selection was to begin, appellee asked for leave to represent himself, and asked for a continuance to prepare his defense. The trial court surmised that appellee's latest request was a delaying tactic and denied the continuance. The Superior Court reversed the trial court's decision, ruling that it was error to deny appellee's last continuance request. The Commonwealth appealed the Superior Court's decision. The Supreme Court concluded the trial court did not abuse its discretion under the circumstances of this case, vacated the Superior Court's reversal, and reinstated appellee's conviction and sentence. View "Pennsylvania v. Brooks" on Justia Law

Appellant Terry Taylor was sentenced for driving under the influence of alcohol or a controlled substance (DUI), without a “full assessment for alcohol and drug addiction,” which is required “prior to sentencing” by Section 3814(2) of the Vehicle Code, 75 Pa.C.S. sec. 3814(2). His sentence was imposed without consideration of the drug or alcohol treatment recommendations that an Assessment may have provided. Appellant, argued that he was entitled to have his sentence vacated, to be assessed in compliance with Section 3814(2), and to be resentenced after consideration of any treatment recommendations. The Superior Court rejected this argument, and upheld his judgment of sentence. Because the Supreme Court agreed with Appellant that the presentence requirement of Section 3814(2) was a mandatory component of the sentencing scheme for DUI offenders, and that a sentence imposed contrary to these requirements cannot stand, the Court reversed and remanded for resentencing after compliance with Sections 3804, 3814, and 3815 of the Vehicle Code. View "Pennsylvania v. Taylor" on Justia Law

In the Highland Garden neighborhood of the City of Chester, during the evening O'Neil Blackwood suffered a fatal gunshot wound to his head during a burglary of his home by three assailants who intended to steal cash and drugs from Victim. The assailants also assaulted his wife, while their young children were upstairs in the home. Mrs. Blackwood identified defendant Shaatan Adams as one of the assailants, although his face was covered by a clear or flesh-toned mask. Moreover, at trial, one of Defendant’s co-conspirators testified against him in exchange for a reduction of charges. A neighbor also testified to overhearing Defendant and the other assailants preparing for the crime. The Pennsylvania Supreme Court granted review to consider whether the right against self-incrimination, as protected by the United States and Pennsylvania constitutions, was implicated when a Commonwealth witness, such as an investigating detective, testified without adverse implication that the defendant refused to answer questions prior to arrest. As observed in the majority opinion in "Commonwealth v. Molina,"( __ A.3d __ (J-55-2013) (Pa. 2014) addressing the question of whether an arguably exploited reference to a defendant’s pre-arrest silence violated the defendant’s right against self-incrimination under the Pennsylvania Constitution), the Supreme Court affirmed the superior court's conclusion that defendant’s constitutional rights, in this case, were not violated by the detective’s testimony in this case. View "Pennsylvania v. Adams" on Justia Law

A jury convicted defendant Michael Molina of third degree murder and related crimes resulting from the savage beating of Melissa Snodgrass, apparently as a result of drug debts owed by Victim to Defendant. The victim told her mother, with whom she lived, that she was leaving the house to run some errands. When she did not return, the victim's mother reported her disappearance to the Missing Persons Unit of the Pittsburgh Police Department. Six months later, her decomposed remains were found under moldy clothing and other debris in the basement of a house in the Spring Garden section of Pittsburgh in which Michael Benintend, one of the prosecution’s primary witnesses, resided during the relevant time period. The issue this case presented for the Supreme Court's review centered on the Missing Persons Unit detective’s testimony and the prosecutor’s closing arguments regarding the early days of the investigation into the victim's disappearance. Following a lead that Defendant was holding the victim against her will, the Missing Persons Unit detective assigned to the case went to Defendant’s house two days after Victim’s disappearance. Pamela Deloe, another prosecution witness, answered the door and asserted that neither the victim nor Defendant were at the house. Accordingly, the detective left her card and asked that Defendant call her. Later that day, Defendant called the detective. The detective then inquired as to when Defendant had last seen the victim. He initially responded that he had not seen her for a year and a half, but then he immediately contradicted his statement, claiming instead that he had not seen her for three months. Subsequent to this contradiction, the detective testified that she asked him to come to the police station to speak to her and he refused. The Supreme Court granted review in this case to consider whether a defendant’s right against self-incrimination is violated when the prosecution utilizes a non-testifying defendant’s pre-arrest silence as substantive evidence of guilt. This was an issue of first impression, to which the United States Supreme Court had not definitively spoken. The Pennsylvania Court agreed with the Superior Court, as well as several sister courts, that the use of pre-arrest silence as substantive evidence of guilt violates a non-testifying defendant’s constitutional rights. The Pennsylvania affirmed the order of the Superior Court remanding for a new trial. However, given that the status of federal jurisprudence was uncertain, the Court based its holding in this case upon the right against self-incrimination set forth in Article I, Section 9 of the Pennsylvania Constitution. View "Pennsylvania v. Molina" on Justia Law

In 2009, intervenor-requestor James Schneller of Eastern Pennsylvania Citizens Against Gambling, sent an email to Catherine Stetler, a press aide in the Office of Communications and Legislative Affairs of the Pennsylvania Gaming Control Board (“GCB”), requesting copies of communications between the GCB and several applicants for gaming licenses, as well as copies of the financial data that each applicant provided to the GCB. He also asked for permission to speak at the GCB’s next public hearing, and copied his request to the GCB’s Director of Media Relations and Chief Enforcement Counsel. It was undisputed that requestor did not make mention of any open-records officer in his written request. The press aide responded to the written request by return email, wherein she apologized for having been out of the office and attached a public comment sign-up form with instructions to return the completed form for permission to comment at the GCB’s public hearing on the following day. The aide did not otherwise respond to the request for records, and did not forward the request to the GCB’s open-records officer. The issue this case presented for the Supreme Court's review centered on the requirements for written Right-to-Know-Law (RTKL) requests for access to public records, the proper application of the provision which directs that all such requests “must be addressed to the open-records officer.” The Court held that in order to establish a valid RTKL request sufficient to trigger appellate rights from a nonresponse under the RTKL, the requestor must address his request to the respective open-records officer as mandated in Section 703. View "PA Gaming Control Brd. v. Office of Open Records" on Justia Law

Appellees Henry Daniels and Kevin Pelzer participated in a plan to kidnap and hold for ransom sixteen-year-old Alexander Porter. Appellees kidnapped the victim, bound and gagged him, and placed him in the trunk of his car. Ultimately, they determined to kill the victim. In all, the victim was held in the trunk for twenty-four hours. According to appellees' police statements and Daniels's trial testimony, appellees were unable to determine whether the youth was dead when they went to dispose of his body. Pelzer shot Porter four times in the back of the neck to remove all doubt. The jury found both appellees guilty of first-degree murder and other offenses. These cross-appeals were a continuation of their first collateral challenges to their convictions under the Post-Conviction Relief Act ("PCRA"). The Pennsylvania Supreme Court vacated the PCRA court's March 25, 2003 order, which had granted appellees a new trial. The Court reviewed three claims of trial counsel ineffectiveness, denied relief on all three claims, and remanded the case to the PCRA court for the preparation of an opinion addressing the remainder of appellees' claims. On remand, the PCRA judge retired, a new judge ordered a new penalty proceeding for each appellee, while denying guilt phase relief. The Commonwealth appealed that order, while appellees, in separate cross-appeals, sought review of additional issues upon which the PCRA court denied relief. Upon careful consideration of the record below, the Supreme Court affirmed the order of the PCRA court as it related to Kevin Pelzer, but reversed the order as it related to Henry Daniels. Thus, Pelzer was denied guilt phase relief, but the award of a new penalty phase hearing to him was affirmed, and Daniels's PCRA petition was dismissed in its entirety. View "Pennsylvania v. Daniels" on Justia Law

In an appeal by allowance, the issue before the Supreme court was whether a conviction for possession of an instrument of crime ("PIC") could be sustained when a defendant has been otherwise acquitted of related offenses involving the use of that instrument of crime, here, a firearm. Upon review of the facts of this case, the Supreme Court held that a defendant's conviction of PIC may stand under such circumstances. The Court vacated the Superior Court's order reversing Appellee James Moore's PIC conviction, and remanded to the trial court for reinstatement of Appellee's judgment of sentence. View "Pennsylvania v. Moore" on Justia Law

The issue this case presented for the Pennsylvania Supreme Court's review centered on the viability of the historic police power of the state in validating and regulating riparian rights and remedies where it was alleged that a downstream landowner subject to federal rail-safety regulations obstructed a natural watercourse causing upstream flooding and significant damage as a result. Hotel owner David Miller and his hotel (appellants) sought to hold the Southeastern Pennsylvania Transportation Authority ("SEPTA") liable for water damage allegedly resulting from the negligent construction and/or maintenance of a nearby SEPTA-owned railroad bridge. Appellants purchased hotel property in 1996, and they claimed that the bridge thereafter obstructed the flow of a creek which ran under the bridge, causing the creek to flood appellants' upstream hotel on three separate occasions of extreme weather conditions. On each occasion, appellants experienced flooding that filled the hotel basement and first floor. In 2001, the hotel closed and appellants declared bankruptcy. "As this is an area of law that has been regulated by the Commonwealth for centuries," the Pennsylvania Court concluded that there was no clear and manifest federal congressional intention to preempt Pennsylvania law central issue of this case. The Court declined to "invalidate the rights and remedies afforded to appellants under the laws of this Commonwealth." The Court reversed the Commonwealth Court's order and remanded this case for further proceedings. View "Miller v. SEPTA" on Justia Law

The Superior Court affirmed the trial court’s dismissal of this case for improper venue. A criminal complaint was filed in Monroe County charging appellant with criminal conspiracy, firearms not to be carried without a license, possession of firearm prohibited, and lending or giving of firearms prohibited. Venue was held improper based on a lack of factual connection to Monroe County. Upon review, the Supreme Court concluded this was error. The case was remanded to the trial court for further proceedings. View "Pennsylvania v. Gross" on Justia Law

In an appeal by allowance, the issue this case presented to the Pennsylvania Supreme Court was whether first-degree burglary constituted “violent behavior” pursuant to the Recidivism Risk Reduction Incentive Act (“RRRI Act”). The Court concluded that first-degree burglary is “violent behavior” as contemplated by the RRRI Act. Thus, the Court affirmed the decision of the Superior Court upholding Appellant Matthew Chester's sentence. View "Pennsylvania v. Chester" on Justia Law