Justia Pennsylvania Supreme Court Opinion Summaries

Appellant Anthony Reid was convicted by jury of first-degree murder, carrying a firearm without a license, possessing an instrument of crime, and criminal conspiracy stemming from the 1988 murder of Mark Lisby. Appellant was ultimately sentenced to death for the first-degree murder conviction, 2.5 to 5 years for possession of an instrument of crime, 2.5 to 5 years for carrying a firearm without a license, and 5 to 10 years for criminal conspiracy. Appellant filed for post-conviction relief, and was denied. He appealed to the Pennsylvania Supreme Court. Finding no reversible error, the Supreme Court affirmed the PCRA court's denial of relief. View "Pennsylvania v. Reid" on Justia Law

In 1989, a group of boys was throwing snowballs at passing cars in a Philadelphia neighborhood. One of the snowballs struck a vehicle driven by Appellant Anthony Reid, who was also known as “Tone” or “Tone-Bey.” Appellant stopped his vehicle, and he and his two passengers exited the car. The boys scattered, and Appellant asked two bystanders if they were involved in throwing the snowballs. The bystanders denied involvement, and, as Appellant reached his hand inside his jacket, he replied “You better hope none was your family.” Appellant and his passengers drove around the block looking for the boys who had been throwing snowballs. When Appellant reached the stop sign, he drove the car onto the sidewalk and gunfire erupted from the passenger side of the vehicle. Michael Waters was fatally wounded. Six days later, in a separate incident, Appellant used a 10-millimeter handgun to kill Neal Wilkinson. In this incident, Appellant and a companion, Kevin Bowman, asked Wilkinson and Darryl Woods to accompany them to collect a debt. When Wilkinson and Woods ascended the stairs to the residence of the alleged debtor, Bowman shot them both with a shotgun, and Appellant then shot both men with a handgun. Woods survived and gave police a statement naming Appellant as one of the two shooters. Ten-millimeter shell casings found at the scene of the Wilkinson murder were determined to have been fired from the same gun that was used in the Waters murder six days earlier. The trial court formally imposed a death sentence on the murder conviction, and a consecutive aggregate sentence of 10-20 years imprisonment on remaining offenses. Appellant sought post-conviction relief, but was denied. Finding no reason to overturn the PCRA Court's decision, the Supreme Court affirmed. View "Pennsylvania v. Reid" on Justia Law

Following remand in this capital case, the Commonwealth appealed the Court of Common Pleas of Philadelphia County's order granting Appellee Richard Hackett's petition pursuant to the Post Conviction Relief Act (PCRA). After determining that Appellee proved he was "mentally retarded" and thus, exempt from execution in accordance with the United States Supreme Court's decision in "Atkins v. Virginia," (536 U.S. 304 (2002)), the PCRA court set aside Appellee's death sentence. As the PCRA court made findings which were not supported by substantial evidence of record and made an error of law by improperly equating borderline intellectual functioning with mental retardation (intellectual disability), the Supreme Court reversed the PCRA court's order vacating Appellee's death sentence and dismissed his petition for collateral relief. View "Pennsylvania v. Hackett" on Justia Law

Wes and Cynthia Collier lived in a home in Scranton, Pennsylvania with their children and step-children: 16-year-old Leslie Collier; 19-year-old Samantha Hintz; 22-year-old Dustin Hintz; and 22-year-old Matthew Collier, who was handicapped and could not walk. Appellee, then 25-years-old, moved into the Collier home. At the time, he and Samantha were boyfriend and girlfriend, and they lived in her bedroom. Between May and June 2008, Samantha and Appellee were no longer getting along, so Appellee was given his own bedroom in the basement. Appellee became angry when he found Justin Berrios, age 22, Samantha’s former boyfriend and the father of her 2-year-old child Tristan, sitting on Samantha’s bed with her. After working their shifts, Samantha gave Appellee a ride home. Appellee left for a friend’s house, and Cynthia retired for the evening at 11:00 p.m. In the early hours of July 17, 2008, Appellee returned to the Collier home and stabbed Justin to death. When police arrived at the house, they found Samantha, Cynthia and Matthew bound. Samantha had been assaulted; Justin, Leslie and Dustin were dead. Appellee was charged with three counts each of first-degree murder, second-degree murder and third-degree murder, robbery, indecent assault and kidnapping, and convicted by jury on all counts. A three-judge panel of the Superior Court, in relevant part, unanimously determined the facts were insufficient to sustain the kidnapping charge, and, as a result, the second-degree murder convictions. The Commonwealth appealed the Superior Court's judgment. Finding that the victims, although imprisoned in their home, nevertheless, were confined in a place of isolation, satisfied the Commonwealth’s definition of kidnapping. Thus, the Superior Court was reversed and the trial court's judgments of sentence reinstated. View "Pennsylvania v. Rushing" on Justia Law

A Pittsburgh police officer on foot patrol came upon Appellant Duane Jemison, Jr.'s car which was parked improperly in a legally marked handicapped parking spot. Upon running the car's license plate number, the officer discovered that the car had been carjacked a few days before. As other officers arrived at the scene, Appellant entered the car and started to drive away, but was immediately stopped by a police vehicle in his path. The officers ordered Appellant to get out of the car. Rather than complying immediately, Appellant moved one of his hands downward toward the floorboard, where one of the officers then observed a gun. After a search, officers recovered a gun with the hammer back, the safety off, and a round in the chamber from the floor of the vehicle. Appellant was charged with persons not to possess a firearm, carrying a firearm without a license, resisting arrest, and two counts of receiving stolen property. He was tried by jury for persons not to possess a firearm, after this charge had been severed from the others. To establish Appellant's guilt of this charge, the Commonwealth was required to prove that Appellant had been previously convicted of a statutorily enumerated offense that barred him from possessing a firearm, and that he had, indeed, possessed a firearm. It was undisputed that, in 2008, Appellant had been convicted of robbery, and the Commonwealth sought to introduce at trial the evidence of this robbery conviction. However, Appellant sought to stipulate only that he had been convicted of one of the enumerated offenses, without stating that the specific offense was robbery. The issue this case presented for the Supreme Court's review was the continued viability of "Commonwealth v. Stanley," (446 A.2d 583 (Pa. 1982)), where the Court held that the prosecution was not required to accept a defendant's offer to stipulate to the fact of a prior conviction when the conviction was an element of the offense charged. Concluding that "Stanley" remained good law despite the United States Supreme Court's holding in "Old Chief v. United States," (519 U.S. 172 (1997)), the Pennsylvania Court affirmed the Superior Court's order affirming Appellant's sentence. View "Pennsylvania v. Jemison Jr." on Justia Law

The Pennsylvania Turnpike Commission filed a petition for review of an order of the supervising judge of the Thirty-Third Statewide Investigating Grand Jury (Dauphin County) which denied the Commission’s motion for a protective order seeking to prohibit the Office of Attorney General from reviewing allegedly privileged or protected communications between the Commission and its counsel. Finding no reversible error, the Supreme Court affirmed the denial of the Commission's petition. View "In Re: 33rd Statewide Investigating Grand Jury" on Justia Law

The Commonwealth appealed a Superior Court order that held a trial court was required to determine whether a child victim was competent to testify prior to admitting to her out-of-court statements into evidence under the Tender Years Hearsay Act (TYHA). Upon review of the facts of this case, the Supreme Court reversed the Superior Court, holding that a determination of a child's competency under the rules of evidence is not a prerequisite to the admission of hearsay statements under TYHA. View "Pennsylvania v. Walter" on Justia Law

Appellant Imanuel Bassil Ali appealed the dismissal of his second petition for collateral relief under the Post Conviction Relief Act as untimely filed. Appellant argued he suffered from mental incompetency at relevant times during his first PCRA proceedings so as to qualify his second PCRA petition for the newly-discovered evidence exception to the PCRA time-bar. Because he failed to establish his claim by a preponderance of the evidence, the Supreme Court affirmed the dismissal. View "Pennsylvania v. Ali" on Justia Law

In a medical malpractice case, the issue presented for the Supreme Court's review centered on whether the trial court properly gave an "error in judgment" jury instruction. The underlying case arose out of the death of a two-month-old child while under the care of his pediatricians. Appellees sued the pediatricians. Their experts testified that the doctors deviated from the standard of care by failing to refer the child for further testing. The trial judge held a charging conference and stated that all of the doctors' proposed points for charge would "either be read or covered." The judge, however, did not say which (if any) proposed changes would actually be read to the jury. Appellees did not object at the time. The judge then proceeded to discuss one of the doctors' proposed "error in judgment" charge. Counsel for Appellees objected that the instruction was inappropriate for this case. The judge ultimately included the "error in judgment" charge when instructing the jury. The jury later ruled in the doctors' favor. Appellees filed timely post-trial motions arguing, among other things, the trial court erred in giving the "error in judgment" charge. Approximately one month after Appellees filed their post-trial motions (and before the trial court ruled on those motions), the Superior Court filed its decision in "Pringle v. Rapaport," (980 A.2d 159 (Pa.Super. 2009)). In that case, the trial court had given a charge very similar to the one given here. Approximately one year later, the Superior Court decided Pringle, holding: "such an instruction should never be given because it 'wrongly suggests to the jury that a physician is not culpable for one type of negligence, namely the negligent exercise of his or her judgment.'" The trial court here denied Appellees' post-trial motions and entered judgment in the doctors' favor. The Supreme Court concluded the Superior Court applied Pringle correctly to the circumstances of this case. The case was remanded to the trial court for further proceedings.View "Passarello v. Grumbine" on Justia Law

Appellee Christopher Williams was convicted of first degree murder and subsequently sentenced to death for the murders of three men in September of 1989. The Supreme Court affirmed the sentence on direct appeal. Appellee then sought post-conviction relief. The PCRA court initially granted Appellee relief on a basis unrelated to this appeal. The Supreme Court subsequently reversed the PCRA court and remanded for disposition of Appellee's remaining claims. On remand, the PCRA court granted Appellee a new trial, finding that trial counsel rendered ineffective assistance by failing to investigate medical and forensic evidence and finding that appellate counsel likewise rendered ineffective assistance by failing to argue on appeal that the trial court erred when it limited cross-examination of the Commonwealth's expert witnesses. Thirty days after the PCRA court entered its order granting Appellee a new trial, the Commonwealth electronically filed with the Philadelphia County Clerk of Courts a notice of appeal and jurisdictional statement appealing the grant of a new trial to the Supreme Court. The Clerk sent the Commonwealth an electronic confirmation indicating that the notice of appeal was received. Nonetheless, the Clerk refrained from time-stamping the notice of appeal on that date. Instead, the following day, the Clerk informed the Commonwealth that its notice of appeal was defective because it was missing two docket numbers and/or because the Clerk's office preferred a separate notice for each of the three docket numbers contained therein. The Commonwealth filed an amended notice of appeal that the Clerk accepted and time-stamped upon receipt. Appellee filed a Motion to Quash the Commonwealth's appeal with the Supreme Court, arguing that the appeal was untimely because the Commonwealth failed to file it within thirty days of the PCRA court's order, assuming the Commonwealth filed its notice of appeal on the date the Clerk time-stamped the amended appeal. Appellee argued the Supreme Court lacked jurisdiction to hear the appeal because of the amended filing. Finding no reversible error, the Supreme Court found the Commonwealth's appeal as timely, and denied Appellee's Motion to Quash. View "Pennsylvania v. Williams" on Justia Law