Justia Pennsylvania Supreme Court Opinion Summaries

The question presented to the Supreme Court in this case was whether a criminal defendant’s right to be present in the courtroom at every critical stage of his or her trial, including during the impaneling of a jury, categorically mandates the defendant’s personal ability to hear each venireperson who is questioned at sidebar during voir dire proceedings conducted by the court, his counsel, and the prosecuting attorney as to substantive issues. The Supreme Court concluded that it did not based upon the principle that a defendant’s right to be present in the courtroom at every stage of his or her trial is not absolute, and that under certain circumstances, including where the defendant is physically present in the courtroom and is represented by counsel, the right to be present at every stage of trial is vindicated without the defendant’s being personally able to hear the questioning of each venireperson at sidebar. Because Appellant Christian Hunsberger was physically present in the courtroom during sidebar voir dire proceedings, was represented by counsel, and interacted with counsel during these proceedings, his claim that counsel was ineffective for failing to advise him that he had a right to be present at sidebar was "without arguable merit." Accordingly, the Court affirmed the order of the Superior Court denying relief. View "Pennsylvania v. Hunsberger" on Justia Law

The issue before the Supreme Court in this case centered on whether a Workers' Compensation employer's insurance carrier should be reimbursed from the Supersedeas Fund for specific payments made to a claimant prior to the ultimate grant of supersedeas. The question turned on whether the relevant payments constituted payments of "compensation" within the meaning of Section 443 of the Workers' Compensation Act (WCA), 77 P.S. 999(a), or, as argued by Appellant Bureau of Workers' Compensation, whether the payments are not reimbursable because they constitute payment of legal costs associated with obtaining a claimant's third-party tort settlement under Section 319 of the WCA, 77 P.S. 671. After review, the Court found no language in either Section 443 or Section 319 that would transform the relevant payments into something other than compensation merely because the amounts of the payments were calculated to compensate the claimant for the costs of recovering the third-party settlement. Accordingly, the Court affirmed the decision of the Commonwealth Court. View "Bureau of Workers' Comp, Aplt v. WCAB(Excelsior Ins.)" on Justia Law

Appellant Donte Thomas directly appealed his death sentence for first degree murder to the Supreme Court. On appeal, he argued prosecutorial misconduct, errors at trial and ineffective assistance of counsel as grounds for reversal. Following a review of the facts and trial court record, the Supreme Court concluded there was no misconduct, no errors by the trial court, and that Appellant received effective assistance of counsel. Accordingly, the Court affirmed Appellant's sentence. View "Pennsylvania v. Thomas" on Justia Law

Following several evidentiary hearings in this post-conviction capital case, the Court of Common Pleas of Berks County (PCRA court) dismissed the petition filed by Appellant Jose Busanet pursuant to the Post Conviction Relief Act. Appellant filed his PCRA petition on September 24, 2004, and amended it on December 14, 2004. Upon Appellant’s motion, the PCRA court judge, who had presided over Appellant’s trial, recused himself from the PCRA proceeding based on general comments the judge had made in an unrelated case, which referenced his frustration with cases involving drug dealing and gun violence in the City of Reading. A new PCRA court judge was assigned to the case. During the next few years, several different counsel withdrew their appearance due to conflicts of interest. Appellant filed amendments to his PCRA petition on September 14, 2007, and January 7, 2009. On February 7, 2011, the PCRA court entered an Order and Opinion, examining thoroughly each of Appellant’s several claims, and denying PCRA relief. In his direct appeal from the denial of PCRA relief, Appellant raised thirteen issues. Upon careful consideration of each of Appellant's issues raised on appeal, the Supreme Court found no error, and affirmed the PCRA Court's dismissal the PCRA petition. View "Pennsylvania v. Busanet" on Justia Law

Following the death of a college student in Shippensburg, Hearst Television, Inc., d/b/a WGAL-TV and its reporter, Daniel O'Donnell (Requester), filed a Right to Know Law (RTKL) request with Michael Norris, the Coroner of Cumberland County (Coroner), seeking the student's manner of death. The Coroner rejected the request, and the Pennsylvania Office of Open Records (OOR) upheld the Coroner's decision. On appeal, the trial court and the Commonwealth Court affirmed. The Supreme Court reversed, holding that under Section 1236.1(c) of the Coroner's Act and the under the RTKL, the record indicating the manner of death was immediately available to Requester. View "Hearst Television Inc. v. Norris" on Justia Law

The issue on appeal in this case was one of first impression: whether a medical general practitioner who provides incidental mental health treatment to a patient, with whom he then engages in a sexual affair, may be held to a particularized "specialist duty," applicable to mental health professionals, that prohibits consensual sexual contact with patients, such that the defendant general practitioner may be subject to medical malpractice liability in tort. Upon review of the trial court record, the Supreme Court declined to impose such a duty as a matter of Pennsylvania common law. Accordingly, the Court vacated the Superior Court's decision and remanded the case for further proceedings on any preserved issues remain that were not addressed as a result of the Superior Court's disposition. View "Thierfelder v. Wolfert" on Justia Law

This appeal presented a discrete issue of post-trial procedure governed by Rule 227.1 of the Pennsylvania Rules of Civil Procedure, which requires a party to file posttrial motions with the trial judge within ten days of certain enumerated events, with the failure to so file resulting in the significant consequence of a waiver of issues on appeal. The specific question presented was whether a party must file post-trial motions in a remand scenario -- here, a circumstance where, on remand from the Superior Court, the trial court recalculated a damage award without receiving any additional evidence from the parties. The Superior Court quashed appellants' appeal from the trial court's recalculated damages order, holding that appellants had waived all claims by failing to file a second round of post-trial motions. This implicated the question of whether a trial occurred on remand, thereby triggering the post-trial motion procedure contemplated by Rule 227.1. Upon review, the Supreme Court concluded that the panel erred in deeming appellants' claims to be waived for non-compliance with Rule 227.1. Accordingly, the Court vacated the quashal order below and remanded the case for consideration of the merits. View "Newman Development Group of Pottstown v. Genuardi's Family Markets" on Justia Law

Appellant Aaron Jones' third petition for PCRA relief was denied as untimely, and he appealed to the Supreme Court. Appellant was convicted of first degree murder and sentenced to death for ordering the murder of a rival gang member. After multiple unsuccessful attempts to get PCRA relief, Appellant filed an unsuccessful petition for the writ of habeas corpus. When that too was denied, Appellant filed a third PCRA petition, alleging that he received newly-discovered evidence and that his untimely petition should be excepted from the PCRA's timeliness requirement. Upon review, the Supreme Court found no merit to Appellant's arguments, and ruled that his petition was clearly untimely and properly dismissed by the PCRA court. View "Pennsylvania v. Jones" on Justia Law

The Supreme Court granted review of this case to address the applicability of Section 9543(b) of the Post Conviction Relief Act (PCRA) to delays in filing amended post-conviction petitions, and the related issue of what obligation (if any) a petitioner had to move the litigation of his petition forward. In 1988, Petitioner filed a pro se application for post-conviction relief. A public defender was appointed to serve as his counsel upon remand to the PCRA court, but no further docket entries appeared in Petitioner's case until 2003 when Petitioner acting pro se filed a document seeking "extension of post-conviction relief petition." The extension was treated as an untimely and successive PCRA petition. On remand, the case was again assigned counsel, and that counsel filed an amended PCRA petition, raising numerous claims regarding Petitioner's trial counsel's ineffective assistance. The PCRA court issued an opinion dismissing the matter with prejudice. The court cited that too much time as passed to be able to mount a defense as fifteen witnesses were no longer available: "the absence of witnesses as well as the likelihood that memories would be poor twenty-four years after trial… would severely prejudice the Commonwealth's ability to retry" Petitioner. Accordingly, the PCRA court dismissed the matter; the Superior Court affirmed. Upon review the Supreme Court affirmed, concluding that the Legislature balanced policy concerns implicated by protracted litigation of PCRA claims and determined that in certain instances of substantial delay, the prejudice suffered by the Commonwealth as a result of that delay, as demonstrated at an evidentiary hearing, justifies dismissal of an original or amended petition. View "Pennsylvania v. Renchenski" on Justia Law

In 1996, the Pennsylvania Supreme Court granted mandamus relief and ordered the General Assembly to enact laws to provide funding for the support of judicial system. In 1999, the General Assembly enacted legislation which effectuated the first phase of an appointed master's recommendations for implementation of the Court's directive. In late 2008, the Petitioners in this case filed a "Motion to Enforce Grant of Petition for Mandamus and Order" requesting that the Court enforce the 1996 order. Upon review of the years' of litigation since 1996 in this matter, the Supreme Court elected not to grant further mandamus relief, "and neither [was the Court] inclined to go backward and overrule [its] prior decisions rendered in light of the realities of time." The Court denied the motion to enforce and relinquished jurisdiction. View "PA State Association of County Commissioners v. Pennsylvania" on Justia Law