Justia Pennsylvania Supreme Court Opinion Summaries

Appellees owned a 166-acre farm in Lower Makefield Township. On December 6, 1996, Lower Maker Township condemned the property in order to build a public golf course. Appellees filed preliminary objections challenging the validity of using eminent domain for such a purpose. That issue was eventually appealed to the Commonwealth Court, which found the taking was for a legitimate public use. As the parties were unable to agree on damages, the matter proceeded to a jury trial for a calculation of the property's value. The trial lasted six days, and a total of 11 witnesses were called, one of whom was appellee Chester Dalgewicz. Mr. Dalgewicz testified regarding the farm's history and the interest shown by several developers in purchasing the property, and described some of the offers received both before and after the property was condemned, including a 1995 agreement of sale with Ryland Homes for $5.1 million, and a 1998 sales agreement with Toll Brothers for $7 million, contingent upon the condemnation being overturned. During Mr. Dalgewicz's testimony, he described a December, 1998 written offer from Pulte Homes, Inc., including a $8 million offer price; the offer letter was also introduced into evidence. The Township objected arguing the offer was inadmissible as it did not result in a sales agreement and any testimony concerning the offer price would be irrelevant and prejudicial. The Township appealed the Commonwealth Court's order affirming the trial court's ruling that testimony regarding a bona fide offer and the underlying offer letter itself could be introduced into evidence in a condemnation valuation trial. Finding no error, the Supreme Court affirmed the lower courts' decisions. View "Lower Maker Township v. Lands of Chester Dalgewicz" on Justia Law

Appellant Paul Gamboa Taylor appealed the PCRA court's dismissal of his third PCRA petition as untimely and finding trial counsel did not have a conflict of interest during his representation of appellant. Appellant, through PCRA counsel, filed a third PCRA petition alleging, for the first time, at the time he entered his guilty pleas, trial counsel had a conflict of interest which adversely affected his representation of appellant. Appellant contended trial counsel's representation of a a family member of his victim, and that representation was a conflict of interest. Specifically, appellant contended this conflict of interest caused trial counsel to abandon appellant's interests and begin working against him. The Commonwealth filed a motion to dismiss the third PCRA petition as untimely. The PCRA court ultimately determined trial counsel did not have an actual conflict of interest during his representation of appellant. Based on this determination, the PCRA court concluded there was no newly-discovered evidence of a conflict of interest that would bring appellant's petition within one of the PCRA's timeliness exceptions. Accordingly, it found the petition untimely and denied it. Upon review, the Supreme Court agreed, and concluded that the PCRA court properly found appellant failed to satisfy the newly-discovered evidence exception. His third PCRA petition was, therefore, untimely. View "Pennsylvania v. Taylor" on Justia Law

In 2007, police received information from a concerned citizen who witnessed a possible drug transaction at appellee's residence. Police investigation revealed appellee had five prior narcotics arrests, and two prior arrests and one conviction for firearms violations. A confidential informant subsequently told police he knew drugs were being sold from appellee's residence. Based on this information, police applied for and executed a search warrant for appellee's residence. After searching the inside of appellee's home, police recovered three guns, soft body armor, drug paraphernalia, and a small amount of marijuana. Appellee admitted sole possession of the contraband and was charged accordingly. Appellee moved to suppress his post-search inculpatory statements and the evidence seized from his home on the grounds the affidavit for the search warrant failed to establish probable cause. At the suppression hearing, appellee argued the affidavit did not specify where the trash was actually located when police seized it. If the trash was on the curb awaiting collection, it was abandoned, and police could lawfully search it without a warrant; if it was on appellee's porch, appellee retained a privacy interest in it, and the trash pull was unlawful. Accordingly, the trial court held the evidence obtained from the trash pulls was properly included in the affidavit, and it denied appellee's motion to suppress. Regarding appellee's challenge to the trial court's admission of testimony not contained in the affidavit, the Superior Court held the trial court violated Pa.R.Crim.P. 203(D) by considering evidence at the suppression hearing that was outside the four corners of the affidavit of probable cause. The court reasoned: [Appellee] was not challenging the trash pull itself, but rather the existence of probable cause on the face of the affidavit. Thus, the question for the trial court was whether sufficient probable cause existed within the four corners of the affidavit to support the magistrate's decision to issue the search warrant. The court concluded, the trial court was prohibited from hearing supplemental testimony on what it deemed a "second constitutional issue" and then using that evidence to determine whether there was probable cause to issue the warrant. After its review of the matter, the Supreme Court concluded that the Superior Court erred in holding the trial court violated Pa.R.Crim.P. 203(D) in the course of deciding whether a search warrant should have been issued; accordingly, the Court reversed. View "Pennsylvania v. James" on Justia Law

The Supreme Court granted allocatur to consider whether a probation condition authorizing warrantless, suspicionless searches of a probationer's home violated statutory and constitutional precepts. In 2007, a Philadelphia police officer observed appellant standing next to a parked automobile. Appellant was pointing a handgun through the passenger window at the driver. The police officer ordered appellant to drop his weapon. Appellant did not comply, but instead, gun in hand, retreated to a nearby residence. The police officer repeated his demand that appellant drop his weapon. Appellant finally complied, and placed himself on the ground in compliance with the officer's direction. The police officer, and a second officer who arrived on the scene in response to a call for back up, retrieved a loaded .38 caliber revolver. Police also recovered seven packets of marijuana and five packets of cocaine from appellant. The trial court instead sentenced appellant to a mitigated-range sentence of 2.5 to 5 years' incarceration, to be followed by three years' probation. The trial court emphasized that there was no stricter probation than Gun Court probation. As a condition of probation and of parole, the trial court authorized warrantless, suspicionless searches of appellant's residence for weapons, and prohibited him from residing in a household where anyone had a firearm. In matters that raise both constitutional and non-constitutional bases for relief, the Supreme Court attempts to resolve matters on non-constitutional grounds as practicable. In this case, the Court found under the applicable statutory construct of this case, sentencing courts were not empowered to direct that a probation officer may conduct warrantless, suspicionless searches of a probationer as a condition of probation. As such, the probation condition ordered in this case was vacated to the extent that the sentencing court found it permissible, and the case was remanded for resentencing. View "Pennsylvania v. Wilson" on Justia Law

Appellant Laquaille Bryant directly appealed his death sentence to the Supreme Court, seeking a new penalty-phased hearing on three grounds: (1) the Suppression Court erred in denying a motion to suppress; (2) the court erred in permitting "extremely inflammatory and prejudicial" photographs of the victim, introduced at the penalty phase hearing; and (3) due to prosecutorial misconduct. Finding no error, the Supreme Court affirmed Appellant's verdict and death sentence. View "Pennsylvania v. Bryant" on Justia Law

This case stemmed from the underground leaking of gasoline from a gasoline station in Blue Bell, Pennsylvania, which caused an explosion in the springhouse of a realty office situated across the street. Many thousands of gallons moved underground throughout the surrounding neighborhoods. Pursuant to Pennsylvania Rule of Civil Procedure 2229(a), 45 affected individuals filed a single complaint against six defendants, alleging that gasoline and vapor from the leak had traveled underground, through soil and groundwater, and had reached and entered their homes, causing property damage to their homes and illness to those living there. At issue before the Supreme Court was whether the Superior Court erred in holding that the trial court abused its discretion in ordering a separate trial of the claims of four test-case, or “bellwether” plaintiffs, from among the 45 plaintiffs. The Court concluded that the Superior Court erred. Furthermore, the Supreme Court held that the Superior Court erred in determining that the trial court abused its discretion in severing the claims in the interest of convenience and judicial economy. The order of the Superior Court was reversed and the jury verdict was reinstated. View "Ball, et al v. Bayard Pump Co." on Justia Law

Appellant Sabrina Bowman appealed a Superior Court’s order affirming the Court of Common Pleas of Philadelphia County, which granted Sunoco, Inc.'s motion for judgment on the pleadings and dismissed appellant's negligence claim. Appellant was employed as a private security guard with Allied Barton Security Services. In exchange for employment, she signed a Workers' Compensation Disclaimer whereby she waived her right to sue Allied's clients for damages related to injuries covered under the Workers' Compensation Act. Appellant was later injured when she fell on ice and snow while working at one of Sunoco's refineries. She filed a workers' compensation claim and received benefits. Thereafter, appellant filed a negligence claim against Sunoco, alleging failure to maintain safe conditions caused her injury. After discovery revealed the disclaimer and appellant's receipt of benefits, appellee filed a motion for judgment on the pleadings, stating appellant's claim was barred by the disclaimer. Finding no error in the Superior Court's decision, the Supreme Court affirmed. View "Bowman v. Sunoco, Inc." on Justia Law

Appellant Stephen Edmiston appealed the denial of relief on two separate Post-Conviction Relief Act (PCRA) petitions: (1) the denial of relief raised in his second PCRA petition; and (2) the denial of his request for post-conviction DNA testing in support of his motion for petition. Upon review, the Supreme Court found that the claims Appellant raised regarding the second petition were untimely. Further more, the Supreme Court affirmed denial of post-conviction DNA testing because Appellant failed to demonstrate that his DNA petition was made "in a timely manner and for the purpose of demonstrating [his] actual innocence and not to delay the execution of sentence or administration of justice." View "Pennsylvania v. Edmiston" on Justia Law

Appellees filed an original-jurisdiction petition for review challenging recent changes to the Department of Public Welfare's practices and policies in determining appropriate reimbursement of county expenditures for out-of-home, child-welfare placement services. According to the petition, the reimbursement scheme as published in the Code, Department regulations, and in previous administrative practices, embodied a needs-based budgeting process supplemented by compliance review via intermittent auditing of county and service provider records by the state agency. Appellees contended however, that DPW through a series of recent administrative bulletins, had unilaterally and inappropriately substituted a restrictive, statewide rate-setting process in place of the prior regime. Appellees lodged substantive and procedural challenges, claiming that the changes effected by the bulletins were ultra vires and unconstitutional, or, alternatively, that DPW had failed to comply with mandatory regulatory-review procedures designed to ensure a meaningful opportunity for public participation and independent regulatory oversight. Upon review, the Supreme Court concluded that the Commonwealth Court did not err in concluding that the bulletins contained procedurally invalid legislative regulations. View "NW Youth Svcs. v. Dept. Pub. Welfare " on Justia Law

Appellant Lewis Jordan, a/k/a John Lewis, pled pled guilty to murder generally in the shooting death of Philadelphia Police Officer Charles Cassidy. Following a trial by jury to determine degree of guilt, Appellant was convicted of first-degree murder and sentenced to death. In a direct appeal, Appellant raised four issues. Concluding that Appellant was not entitled to relief on any of these issues and that the evidence was sufficient to sustain Appellant's conviction, the Supreme Court affirmed the judgment of sentence. View "Pennsylvania v. Jordan" on Justia Law