Justia Pennsylvania Supreme Court Opinion Summaries

In this appeal, the Supreme Court was presented with two questions: (1) whether a defendant's convictions for first-degree murder and other crimes which rest solely on subsequently recanted out-of-court statements given to police violates the due process guarantees of either the United States or Pennsylvania Constitutions; and (2) whether the confessions of a former co-defendant should have been admitted as evidence as statements against interest under Pa.R.E. 804(b)(3). After careful consideration, the Court held that the recanting witnesses' out-of-court statements to the police were sufficient to sustain Appellant's convictions against a due process challenge. However, because the Court also found that the trial court erred by not allowing other portions of the co-defendant's confessions to be entered into evidence as statements against interest, the Court was "constrained" to vacate Appellant's convictions and remand the case for a new trial. View "Pennsylvania v. Brown" on Justia Law

This direct appeal concerned the Commonwealth Court's jurisdiction over a suit brought by public school employees for injunctive and declaratory relief against the Office of Open Records, seeking to protect the employees' home addresses from disclosure under the Right to Know Law. Due to concerns surrounding the potential disclosure of school employees' names and home addresses under the recently enacted Right-to-Know Law (RTKL), the Pennsylvania State Education Association (PSEA) sought guidance from the Office of Open Records (OOR) in the form of an advisory opinion. The OOR, however, dismissed the request as moot, as it had already issued final determinations directing the release of public records containing school employees' home addresses. Subsequently, numerous RTKL requests were filed with school districts across Pennsylvania, seeking disclosure of the names and home addresses of school employees. Upon discovering that many school districts had not challenged, or would not challenge, the release of such information, PSEA filed a petition for review against the OOR in the Commonwealth Court, seeking preliminary and permanent injunctions prohibiting the disclosure of school employees' names and home addresses and a declaration that such information is exempt from disclosure under the RTKL. PSEA appealed to the Supreme Court, arguing that the Commonwealth Court erred by refusing to exercise its original jurisdiction over their claims for declaratory and injunctive relief. "Plainly, the RTKL, as presently implemented by the OOR, does not provide public school employees with a reliable administrative or judicial method by which to seek redress for action that they believe violates the statutory scheme and/or their constitutional rights. In these unique circumstances, [the Supreme Court had] no difficulty in concluding that it is just and proper for the OOR to be haled into court to address core and colorable issues connected with such treatment at the behest of affected persons and their associations." The Commonwealth Court's decision was vacated and the case remanded for further proceedings. View "Penna. State Education Assn v. Pennsylvania" on Justia Law

The issue before the Supreme Court in this case concerned the propriety of resolutions adopted by two school boards that reduce the compensation rates for elected tax collectors in an effort to adopt alternative collection methods. "[The Supreme Court] recognize[d] the difficulties faced by the School Boards in periods of financial uncertainty, but it is beyond the boards' power to transform the local tax collection system by reducing compensation levels to such a degree that the elected Tax Collectors are unable to fulfill their responsibilities; such systematic change must come from the Legislature." The Court reversed the ruling of the Commonwealth Court and remanded the case for further proceedings. View "Telly v. Pennridge School Dist." on Justia Law

Appellant Bortela Philistin appealed an order that denied him relief from his criminal convictions and death sentence pursuant to the Post Conviction Relief Act. A jury convicted Appellant of first degree murder and related offenses. In the penalty phase, the jury found the existence of two aggravating circumstances: the victim was a police officer killed in the performance of his duties, and the Appellant knowingly created a grave risk of death to another. The jury found no mitigating circumstances; thus, it returned a death sentence. Appellant raised thirteen claims on appeal pertaining to errors at trial, the sufficiency of the evidence presented against him, and ineffective assistance of trial counsel. The Supreme Court found no merit to Appellant's claims, and affirmed his conviction and death sentence. View "Pennsylvania v. Philistin" on Justia Law

The issue before the Supreme Court in this case was whether it is against public policy to release reckless behavior in a pre-injury exculpatory clause. Appellant Camelback Ski Corporation, Inc. (“Camelback”) operates a ski resort in Tannersville, Pennsylvania that offers various winter activities, including skiing and snow tubing. Before permitting its patrons to enjoy snow tubing, Camelback requires each customer to sign a pre-printed release form. In 2003, Appellee Barbara Lichtman Tayar and her family visited Camelback’s facility in the early afternoon. Appellee and her family decided to join in, and, pursuant to Camelback’s requirement, Appellee signed the Release. Appellee and her family elected to use the family tubing slopes, and completed four successful runs down the mountain, with Appellant Brian Monaghan, a Camelback employee, releasing them from the summit safely each time. On the fifth time down the mountain, Appellee exited her snow tube and was immediately struck by another snow tuber coming down the slope. Employees rushed to assist Appellee out of the receiving area. As a result of the collision, Appellee suffered multiple comminuted factures of her right leg, for which she underwent surgery and required two metal plates and 14 screws to stabilize her ankle. A majority of the appellate court determined that the release at issue was valid only with respect to Camelback (and not Monaghan), and relieved Camelback from liability for only negligent conduct. Upon review, the Supreme Court reversed the Superior Court’s order in part, affirmed in part, and remanded the case. The Court reversed the order of the Superior Court to the degree it concluded that Monaghan was not covered by the Release. The Court affirmed the order to the degree it reversed the grant of summary judgment on the basis that the Release did not bar claims based on reckless conduct, and remanded for further proceedings; on the latter point, the Court affirmed on the alternative basis that, to the degree it released reckless conduct, the Release was against public policy. View "Tayar v. Camelback Ski Corp., Inc." on Justia Law

This case was a direct appeal from a Commonwealth Court order which set aside the nomination petition of Andrew Gales as a Democratic Candidate for Pennsylvania State Representative in the 57th Legislative District. On April 4, 2012, the Supreme Court reversed the order of the Commonwealth Court, directed that the candidate’s name be printed on the April 24, 2012 primary election ballot, and indicated that an opinion would follow. The Court released its rationale for that order, and held that the Election Code does not prohibit an elector from signing a nomination petition using an obvious diminutive form of his or her first name, rather than the formal first name that appears on the elector’s voter registration card. View "In re Nomination Petition of Andrew Gales" on Justia Law

The issue before the Supreme Court was whether the Recidivism Risk Reduction Incentive Act (61 Pa. C.C. 4501-4512 (RRRI Act)) applied to defendants sentenced to mandatory terms required by two drug trafficking sentencing provisions. The superior court concluded that the RRRI Act was applicable, and affirmed Appellee Frederick Hansley's sentence. The Commonwealth challenged the trial court's application of the mandatory penalties of the trafficking sentencing provisions, contending: (1) that the trial court lacked the authority to impose lesser minimum penalties than those prescribed by those statutes; and (2) the drug trafficking sentencing statutes conflict with the RRRI Act, and that the plain language of the former provisions established that the General Assembly intended the mandatory penalties to "override" any other conflicting statutes, then-existing or later-adopted. The Supreme Court affirmed, recognizing "that the effect of the RRRI Act may be to reduce the total time in prison that an offender subject to a mandatory minimum sentence must serve. But, it is eminently clear from the plain language of the legislation that the General Assembly intended that result - for a limited class of statutorily defined defendants, upon the completion of several conditions, and subject to the controlling discretion of the Parole Board. [The Court's] plain language interpretation accords with the legislative intent as [it understood] it, and gives effect to all provisions of the relevant sentencing statutes. Accordingly, the decision below is affirmed." View "Pennsylvania v. Hansley" on Justia Law

Appellant Mark Spotz appealed the denial of his petition for collateral relief filed pursuant to the Post Conviction Relief Act (PCRA). Appellant was convicted of first-degree murder for the 1995 shooting death of Penny Gunnet for which he was sentenced to death. Appellant raised numerous issues on appeal; the Supreme Court concluded that there was "no merit" to any of the issues he raised and affirmed the decision of the PCRA court. View "Pennsylvania v. Spotz" on Justia Law

On February 6, 2007, following a narcotics investigation and surveillance operation by the Philadelphia police and the FBI, Nasir Far, Regina Little, and Garnell Brown (collectively, "Appellees") were arrested. Appellees were charged with possession with intent to deliver PCP ("PWID-PCP"), possession with intent to deliver marijuana, possession of drug paraphernalia, and conspiracy. Appellees' cases were commenced in the Court of Common Pleas. Although the cases were listed for a preliminary hearing on several dates, the Commonwealth repeatedly failed to produce a chemical laboratory report of the PCP analysis, without which the Commonwealth could not present a prima facie case for PWID-PCP, and thus the cases were continued. In early 2008, Appellees moved for dismissal of the charges against them based on Pa.R.Crim.P. 1013(A)(4), which governs cases that commence in the Court of Common Pleas, but are subsequently transferred to Philadelphia Municipal Court. The Court of Common Pleas conducted a hearing, wherein the Commonwealth countered that Pa.R.Crim.P. 600, the general prompt trial rule applicable to the Court of Common Pleas applied to Appellees' cases. The court did not agree with the Commonwealth, but rather accepted Appellees' contention that Rule 1013(A)(4) controlled the time frame under which the Commonwealth was required to bring Appellees to trial in the Court of Common Pleas under the circumstances of this case. The question therefore, before the Supreme Court was which statute governed the circumstances of this case. The Court determined that the Superior Court incorrectly applied Rule 1013 to the circumstances of this case. Accordingly the Court reversed the Superior Court and remanded the case for further proceedings. View "Pennsylvania v. Far" on Justia Law

Appellant Willie Sneed appealed the denial of his petition for post-conviction relief. Appellant fatally shot Calvin Hawkins in 1980 after discovering that Hawkins and two accomplices sold him aspirin instead of cocaine. A jury convicted Appellant of first-degree murder and possession of an instrument of crime. The jury found two aggravating circumstances and no mitigating circumstances, resulting in the imposition of the death sentence. Appellant timely filed a pro se PCRA petition. It was discovered shortly before Appellant was scheduled to be executed that no one had reviewed his initial PCRA petition. A stay of execution was granted, and in 2000, Appellant with counsel filed an amended PCRA petition raising twenty-five claims of error. Upon review, the Supreme Court rejected Appellant's allegations of error for "lack of arguable merit." The case was remanded to the PCRA court to conduct a new penalty phase hearing based on the Court's prior decision stemming from Appellant's pro se petition. View "Pennsylvania v. Sneed" on Justia Law