Justia Pennsylvania Supreme Court Opinion Summaries

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

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