Justia Pennsylvania Supreme Court Opinion Summaries

In 2005, Appellees Monroe County Detective Eric Kerchner and First Assistant District Attorney Michael Mancuso were investigating and prosecuting Dennis Slayton for theft and drug-related offenses, as well as Jill Goldstein in connection with the drug offenses. Appellant John P. Karoly, Jr., Esq., was acting as Slayton's attorney. Goldstein appeared at a bail revocation hearing represented by Eric Dowdle, Esq. At the conclusion, bail was revoked and Goldstein was placed in custody at the Monroe County Correctional Facility (MCCF). The next day, Goldstein called Slayton from the jail. During the conversation, Appellant, who was with Slayton, began speaking with Goldstein. The MCCF recorded the conversation. In a direct appeal involving alleged intentional violations of the Wiretap Act, the issue before the Supreme Court was whether the Commonwealth Court erred in granting a defense motion for summary judgment. In the amended complaint, Appellant alleged that Appellees committed multiple violations of the Wiretap Act, most notably that: ADA Mancuso violated Section 5703(2) of the Act by disclosing the conversation between Appellant and Goldstein when he included it in legal filings that were not placed under seal; and ADA Mancuso and Detective Kerchner conspired to transmit such filings to the press. On the basis of this conduct, Appellant asserted that Appellees intentionally violated the statute and, as such, should be removed from their employment pursuant to Section 5726. "In [this] context, the most obvious manner of accomplishing the appropriate investigative and law-enforcement use of the intercepted conversation . . . would have been to file the motion and brief under seal. The failure to do so, as all parties acknowledge, caused the intercepted conversation to become a matter of public record." The Supreme Court found that the Commonwealth Court did not evaluate whether the unsealed filing of the motion and brief was permissible under Section 5717. Because this issue, as well as an appropriate treatment of the alleged disclosure to the press, were material to the outcome, the Court found that the Commonwealth Court improperly granted Appellees' motion for summary judgment. Thus, the case was remanded for hearings on these questions, the question of intent, and/or on whether Appellees acted in good-faith reliance on the Act. View "Karoly v. Mancuso" on Justia Law

At issue in this case was the "interaction" of the attorney-client privilege and the Right-to-Know Law, Act of February 14, 2008, P.L. 6, 65 P.S. secs. 67.101-67.3104 ("RTKL"). In 2010, Associated Press member Marc Levy sent two written requests to the Senate’s Right to Know Officer seeking "all bills, contracts and payment records related to the hiring of any outside lawyer or law firm to represent Sen. Robert J. Mellow beginning Jan. 1, 2009" and the same documents related to "any current or former employee of the Senate Democratic caucus beginning Jan. 1, 2009." The requests came a few days after the media reported that federal authorities executed search warrants on Senator Mellow's home and office as part of a grand jury investigation. After review, the Supreme Court reaffirmed the general rule that client identities are not protected by the attorney-client privilege, but adopted specified exceptions to this general rule. The Court affirmed the Commonwealth Court's determination that general descriptions of legal services included in attorney invoices are not covered by the umbrella of the attorney-client privilege but that specific descriptions that would reveal attorney-client communications are protected. Furthermore, the Court reversed the Commonwealth Court and overturned its decision in "Signature Information Solutions, LLC. v. Aston Township," (995 A.2d 510 (Pa. Cmwlth. 2010)), to the extent it determined that any reasons for denial not raised in the initial written denial of a RTKL request were waived and could not be raised at a later stage of the RTKL process. View "Levy v. Senate of Pennsylvania" on Justia Law

Appellant Rasheed Simpson appealed a court of common pleas order that dismissed his petition without a hearing. In it, appellant sought relief under the Post Conviction Relief Act (PCRA) for his conviction of first degree murder, kidnapping, robbery, conspiracy and possession of an instrument of crime. Appellant was tried jointly with one of his co-conspirators, Malik Bowers. Appellant filed a pro se petition for relief under the PCRA in 2001. Counsel was appointed and filed an amended petition in 2002, and a supplemental amended petition in 2003. The Commonwealth filed a motion to dismiss in 2004. Appellant filed a reply on in 2005, and later that year, the PCRA court granted the Commonwealth's motion without a hearing, concluding Appellant's petition raised no genuine issues of material fact. Upon review, the Supreme Court affirmed the order of the PCRA court with respect to all issues, except Appellant's claim regarding trial counsel's ineffectiveness for failing to elicit testimony concerning the alleged motive and bias of a testifying witness against Appellant, as well as allegations concerning the failure to present other witnesses. The PCRA court's order in this regard was vacated, and the matter remanded back to the PCRA court for further proceedings. View "Pennsylvania v. Simpson" on Justia Law

In 2006, fourteen year old Appellant Qu'eed Batts walked up the front porch steps of a house, shot Clarence Edwards in the head, and shot Corey Hilario in the back as he attempted to flee. Mr. Edwards died on the way to the hospital while Mr. Hilario sustained serious bodily injury but eventually recovered. The issue before the Supreme Court in this case concerned the appropriate remedy for the constitutional violation that occurred when a mandatory life-without-parole sentence was imposed following appellant's first-degree murder conviction. The Superior Court considered the impact of "Miller v. Alabama" (132 S.Ct. 548 (2011)) for determination of age-appropriate sentencing, but the Supreme Court agreed with the Commonwealth's argument that the impact of "Miller" was "minimal" and that the unconstitutional portion of the sentencing scheme was the statute governing parole eligibility which did not distinguish juvenile offenders when stating that parole may not be granted to those serving a life sentence. Because this portion of the statute was severable, the Commonwealth argued that the remaining statutory sentencing provisions of the Criminal Code still required that the court impose a sentence of life imprisonment for a juvenile convicted of first-degree murder. "We find the Commonwealth's construction of the applicable statutes to be the best supported. Appellant's argument that the entire statutory sentencing scheme for first-degree murder has been rendered unconstitutional as applied to juvenile offenders is not buttressed by either the language of the relevant statutory provisions or the holding in Miller." View "Pennsylvania v. Batts" on Justia Law

In an interlocutory appeal, the issue before the Supreme Court in this case concerned the "contours" of the Board of Claims' exclusive jurisdiction pertaining to procurement litigation against state agencies. Specifically, the Court was asked to determine whether such jurisdiction foreclosed original-jurisdiction proceedings in Commonwealth Court, challenging an Department of General Services' (DGS) cancellation of a request for proposals and request for declaratory and injunctive relief. The matter arose from a 2010 DGS request for proposals for the design, development, implementation, and maintenance of a computer control system to monitor slot machines at gaming venues across the Commonwealth. The plan was to replace an existing system which had been provided by Intervenor-Appellant, GTECH Corporation. GTECH and Appellee Scientific Games International, Inc. (SGI), each submitted proposals, and DGS selected SGI for the award and proceeded with contract negotiations. GTECH was informed that the contract had been awarded to SGI and submitted a protest. Two months later, DGS’s Deputy Secretary for Administration issued a final determination denying GTECH’s protest in material part, with prejudice. GTECH appealed the determination and requested, among other things, that the request for proposals be cancelled. Subsequently, DGS announced that it was canceling the request for proposals and sent a letter to SGI indicating "with little elaboration" that the cancelation was in the best interests of the Commonwealth. Subsequently, SGI commenced an action seeking declaratory and injunctive relief against the Departments of Revenue and General Services in the Commonwealth Court’s original jurisdiction and petitioned for a preliminary injunction. Upon review, the Supreme Court concluded that contractors, bidders, and offerors have limited recourse and remedies: "[r]elative to controversies in matters arising from procurement contracts with Commonwealth agencies, the Board of Claims retains exclusive jurisdiction (subject to all jurisdictional prerequisites), which is not to be supplanted by a court of law through an exercise of original jurisdiction. As to challenges to cancellations of solicitations asserted under Section 521 of the Procurement Code, the Legislature did not implement any waiver of sovereign immunity and afforded no remedy to aggrieved bidders and offerors which have not yet entered into an executed contract with a Commonwealth agency." View "Scientific Games Int'l v. GTech Corp." on Justia Law

The Commonwealth appealed a superior court order that quashed an interlocutory appeal of a trial court order that granted Appellee Milton Scarborough's motion for post-conviction DNA testing. Appellee's criminal convictions arose from the robbery and stabbing deaths of a mother and her two children in their home in 1976. Appellee was convicted by a jury of burglary, robbery, theft, conspiracy, and three counts of murder in the third degree. He received an aggregate sentence of 30-60 years incarceration. Appellee pursued a direct appeal, and his convictions and sentence were affirmed by the Superior Court. Appellee next pursued a petition for collateral relief under the former Post Conviction Hearing Act, which was denied by the trial court, and the denial was upheld by the Superior Court. In 2008, Appellee filed his PCRA petition raising two claims for collateral relief: a claim of "after discovered" exculpatory evidence and a "Brady" violation. With respect to the PCRA petition, the court found the petition untimely. With regard to the DNA testing, the court ordered testing of a palm print, fingernail clippings and blood evidence from the scene of the murders. The Commonwealth filed a notice of appeal from the DNA testing order, arguing that the trial court used an incorrect standard in evaluating Appellee’s request for DNA testing, namely, that the trial court considered only whether the DNA testing could be favorable to Appellee, not whether it could establish his actual innocence, which the Commonwealth contended was the proper standard. In the court's opinion, the hearing judge noted the lack of any cases in which the Commonwealth appealed an order granting DNA testing, and suggested that the DNA testing order was "perhaps" interlocutory. Even so, the Commonwealth did not request the court to amend the order to include the necessary certification for a permissive appeal from an interlocutory order, nor did the Commonwealth apply to the Superior Court for permission to appeal the order as required by Pa.R.A.P. 1311(b). Appellee filed an application in Superior Court seeking to have the Commonwealth’s appeal quashed or dismissed on the grounds that it was taken from an interlocutory order. The Commonwealth did not file a response to this application; however, it asserted in the statement of jurisdiction in its brief to the Superior Court that the order granting the DNA testing was final and appealable. The Superior Court subsequently quashed the appeal. After careful review, the Supreme Court concluded that the order granting a motion for post-conviction DNA testing in this case was a final order. Therefore the Court reversed the Superior Court's order and remanded the case for consideration of the merits of the issues presented in the Commonwealth’s appeal. View "Pennsylvania v. Scarborough" on Justia Law

The issue before the Supreme Court in this matter arose from direct appeal of an order that denied injunctive and declaratory relief by an en banc panel of the Commonwealth Court regarding various constitutional challenges to a law enacted by the General Assembly known as "Act 108 of 2011." Specifically, it was alleged that Act 108 was violative of: (1) the "single subject rule" of Article III, Section 3 of the Pennsylvania Constitution; (2) the separation of powers doctrine of Article V, Sections 1 and 10 of the Pennsylvania Constitution establishing a unified judicial system supervised by the Supreme Court; and (3) the due process clause of the Fourteenth Amendment to the United States Constitution under the void for vagueness doctrine. The Commonwealth Court, in a 4-3 decision, rejected the constitutional challenges and dismissed the action. After oral argument and consideration of the Commonwealth Court record, the Supreme Court concluded that with regard to the Article III, Section 3 single subject challenge, Act 108 was unconstitutional. Given this disposition, the Court did not consider the remaining arguments. View "PA State Ass'n of Jury Commissioners v. Pennsylvania" on Justia Law

The issue before the Supreme Court centered on the award of attorney's fees against an insurance company under the peer-review provisions of the Motor Vehicle Financial Responsibility Law (MVFRL). The MVFRL limits the amount providers may charge for treatment, products or services rendered to patients injured in automobile accidents where the injury is covered by an insurance policy. An individual obtained treatment from Appellee Herd Chiropractic Clinic for injuries sustained in a motor vehicle accident. The insurance company submitted the clinic's invoices to a Peer Review Organization (PRO) pursuant to the MVFRL. The PRO determined that certain treatments were not necessary or reasonable, and the insurance company subsequently refused to pay for such treatment The Clinic then sued for unpaid bills, plus treble damages and attorney's fees under the theory that the MVFRL authorized payment. The Common Pleas court found an award of fees proper and mandatory under the MVFRL. The Superior Court affirmed. The Supreme Court, however, reversed, finding that the MVFRL did not allow for what amounted to "fee shifting" by the lower courts' outcome: "We acknowledge [the Clinic's] concerns with the financial incentives in the peer-review industry and with the fact that litigation costs incurred by providers may discourage legitimate challenges. The fee accruals here – in the amount of $27,000 to vindicate a $1380 claim - present a stark example of the difficulty. . . . Nevertheless, fee shifting raises a host of mixed policy considerations in and of itself, which this Court has found are best left to the General Assembly, in the absence of contractual allocation or some other recognized exception to the general, American rule." View "Herd Chiropractic Clinic v. State Farm Mutual Automobile Ins. Co." on Justia Law

The issue before the Supreme Court in this matter concerned the standard of review with respect to a claim that the verdict was against the weight of the evidence. Appellees Jamel Clay, James Claybrook and Rashid Lewis visited "R.B." at her dormitory room in West Chester to socialize. Eventually Appellees, R.B. and her friend H.S. discussed how Appellees would stay the night. H.S. testified that Appellees "ended up" in her room, and did not dispute that she allowed them to stay. Over the course of the stay, the three Appellees engaged in sex with H.S. H.S. contacted her Resident Assistant and claimed that Appellees had raped her. Ultimately Appellees were charged and convicted with the sexual assault of H.S. Each was sentenced to two to four years' incarceration and two years' consecutive probation. Appellees filed a joint motion for post-sentence relief, arguing that the evidence was insufficient to sustain their convictions, and that the jury's verdicts were against the weight of the evidence. Upon review, the Supreme Court concluded that the superior court used the incorrect standard of review and erroneously substituted its own conclusions for those of the jury and the trial court. Accordingly, the Court reversed and remanded the case to the superior court for reconsideration. View "Pennsylvania v. Clay" on Justia Law

The issue before the Supreme Court in this case was whether Appellee John Brock waived his speedy trial claim by either failing to file a written motion to dismiss, or by failing to appear for a trial listing. Upon review, the Supreme Court concluded that under Pa.R.Crim.P. 600, a defendant must file a written motion to dismiss, and that by failing to appear in court on the day his or her case is listed for trial, a defendant waived his Rule 600 claim. Accordingly, the Court reversed. View "Pennsylvania v. Brock" on Justia Law