Justia Pennsylvania Supreme Court Opinion Summaries

The Commonwealth appealed a portion of a superior court order that reversed Appellee Daniel Sinnott's conviction for ethnic intimidation baed in insufficient evidence. Appellee got into a heated argument with his landlord/employer, hurling epithets and throwing things at the landlord and members of his family. Appellee was charged with simple assault, terroristic threats, ethnic intimidation, and possession of instruments of crime. He waived his right to a jury, and the trial court convicted him of all offenses, sentencing him to four to 23 months imprisonment for simple assault and a consecutive four years probation for terroristic threats; no further penalty was imposed. Appellee appealed, challenging the sufficiency of the evidence in support of his terroristic threats and ethnic intimidation convictions. The superior court affirmed the terroristic threats conviction, but reversed the conviction for ethnic intimidation, concluding the record failed to establish the landlord's ethnicity was the "primary basis" for appellee's behavior. In crediting appellee's contention that his conduct was solely motivated by anger with the landlord, the Supreme Court found that the superior court not only imposed a non-existing requirement that racial animus be the sole or primary motivator, but also failed to view the evidence of Appellee's repeated derogatory ethnic slurs in the light most favorable to the Commonwealth as the verdict winner. Accordingly, the Supreme Court reversed the portion of the superior court's order reversing appellee's ethnic intimidation conviction, and reinstate the judgment of sentence for that offense. In all other aspects, the order was affirmed. View "Pennsylvania v. Sinnott" on Justia Law

The issue on appeal before the Supreme Court in this case was whether expert testimony is required to convict a defendant of driving under the influence of a drug or combination of drugs when the drugs in question are prescription medications. Appellee Michelle Griffith was charged with DUI following an eyewitness' account of her driving in a "reckless and dangerous manner." Appellee failed field sobriety tests administered by law enforcement. Diazepam, Nordiazepam and "Soma 350" were detected in her blood which Appellee admitted to taking on the morning of the incident. At trial, two individuals testified: the eyewitness and the responding police officer. The trial court convicted Appellee and sentenced her to three months' imprisonment and a fine. Appellee appealed the conviction, arguing the evidence was not sufficient without testimony of an expert to establish the medications impaired her ability to drive safely. The superior court agreed an expert was needed and vacated Appellee's conviction. The Commonwealth appealed. The Supreme Court reversed the superior court, finding the evidence was sufficient to establish Appellee was under the influence of drugs to a degree that impaired her ability to drive. View "Pennsylvania v. Griffith" on Justia Law

In this capital case, Appellant Ronald Hanible appealed an order of the Court of Common Pleas of Philadelphia County (PCRA court) which denied without a hearing all guilt phase claims raised in his petition for post-conviction relief. Appellant was convicted on two counts of murder. Appellant did not testify on his own behalf or present any witnesses at trial. Instead, he urged the jury to reject the Commonwealth's key witness' testimony as unreliable. Appellant further argued to the jury that none of the physical evidence recovered by police implicated him in the crime. Following the penalty hearing, the jury found two aggravating circumstances and no mitigating circumstances. Accordingly, it returned a verdict of death. Appellant filed a pro se PCRA petition and was appointed counsel. The PCRA court granted a new penalty hearing based on evidence that Appellant's trial counsel failed to present available mitigating evidence. Appellant raised sixteen issues for review to the Supreme Court based on the PCRA's dismissal of his relief petition. The Supreme Court took each in turn, and ultimately affirmed the PCRA court's decision to deny Appellant the relief he requested. View "Pennsylvania v. Hanible" on Justia Law

Consolidating several appeals, the Supreme Court addressed the effect of a municipality's financial distress and recovery planning on an arbitration award agreed to pursuant to the Policemen and Firemen Collective Bargaining Act (Act). For approximately twenty years, the City of Scranton has been designated a distressed municipality under the Municipalities Financial Recovery Act. Pursuant to the Recovery Act, the City has its Commonwealth-mandated financial advisors who assist in creating a financial recovery plan (essentially a budget). In the most recent collective bargaining agreements between the City of Scranton and its Police and Firefighter Unions expired at the close of 2002. Negotiations as to future terms and work conditions for union members resulted in impasses. Accordingly, pursuant to the Act, arbitrators were selected to establish appropriate terms and conditions. Throughout the arbitrations, the City maintained that the arbitrators lacked legal authority to award relief impinging on the City's financial recovery plan. The City attempted to resist paying the ensuing award that resulted from the arbitration. The Commonwealth Court found that it was required to vacate the awards, holding that they did not conform to the City's Recovery Plan and would result in increased financial and operational burdens on an already distressed municipality. The Unions appealed to the Supreme Court. The Court focused on the distinction between the terms "arbitration award" and "arbitration settlement": the City argued that it was not mandated to pay "awards" but "settlements." The Supreme Court found the term "settlement" ambiguous, and the plain meaning could include the "award" given by the arbitrators in this case. Accordingly, the Court reversed the Commonwealth Court's order that the award negatively impacted the City's Recovery Plan. View "City of Scranton v. Firefighters Local Union" on Justia Law

In this discretionary appeal, the Supreme Court reviewed the lower courts' application of the "totality of the circumstances" test for the existence of probable cause necessary to issue a search warrant as set forth by the U.S. Supreme Court in "Illinois v. Gates" and adopted by Pennsylvania in "Commonwealth v. Gray." Specifically, the Court questioned whether the lower courts properly applied the test in determining whether a search warrant was infirm because the affidavit of probable cause failed to expressly attest to the veracity, reliability and basis of knowledge of a confidential informant. Because the totality of the circumstances applied by the trial court in Appellee Steven Clark's case included a factual recitation describing a successful controlled buy of narcotics that corroborated the affiant's averment that the informant was reliable, and because that recitation demonstrated a fair probability that narcotics would be found in the location for which the warrant was sought, the Court determined that the warrant was supported by probable cause. The Court found that the appellate court's suppression of evidence was contrary to its holding here, reversed that court, and remanded the case to the trial court for further proceedings consistent with this opinion. View "Pennsylvania v. Clark" on Justia Law

Appellant Terry Chamberlain appealed the death sentence imposed on him after a jury convicted him of two counts of first-degree murder, burglary and possessing "an instrument of crime" in 1994. On direct appeal, the Supreme Court held that the trial court abused its discretion in denying a pretrial motion for a continuance to allow Appellant to obtain DNA testing of certain blood evidence. The case was remanded for the trial court to allow Appellant to do the testing. The trial court completed proceedings on remand, and the case went back to the Supreme Court for its consideration on the remaining claims in Appellant's appeal. Upon review of those claims, the Court affirmed Appellant's death sentence. View "Pennsylvania v. Chamberlain" on Justia Law

The Supreme Court considered the effect of a pro se notice of appeal which was forwarded to the superior court by a counseled criminal defendant, where counsel, who was not made aware of the pro se notice, subsequently filed a timely post-sentence motion which was denied by the trial court, and then a second timely notice of appeal. In this case, the superior court administratively quashed the counseled-appeal as duplicative, then quashed Appellee Michael Cooper's pro se appeal as premature and void. Yet the court also remanded the case to the trial court for additional review of the counseled post-sentence motion. Upon review, the Supreme Court held that the superior court erred in quashing the appeal and remanding the counseled post-sentencing motion. Therefore, the Court vacated the order and remanded the case back to the superior court for consideration of the merits of Appellee's direct appeal. View "Pennsylvania v. Cooper" on Justia Law

n this appeal, the issue before the Supreme Court was whether the mere offer of an automobile ride to a child constituted an attempt to “lure” the child under Section 2910 of Pennsylvania’s Criminal Code, entitled “Luring a child into a motor vehicle or structure.” Appellant was charged with four counts of harassment, stalking, and attempted luring of a child into a motor vehicle for offering two neighborhood boys a ride to school in Appellant's own neighborhood. He had seen the children in the neighborhood, and offered them short rides to school or to the store. The children declined, and Appellant made no further attempt to "help." Appellant was acquitted of the charged at a bench trial because the judge "expressly stated she found no evidence that Appellant had any intent to harm the children, and that she believed 'the circumstances show no reason to believe that this defendant had any evil or improper intent in doing what he did.'” However, on the sole basis of Appellant’s offer of the rides, she convicted him on all four counts of attempted luring. The trial court found that “[Appellant’s] offer of a ride to the victims is sufficient to constitute an attempt to ‘lure.’” The trial court subsequently sentenced Appellant to 18 months’ probation. As an automatic result of his convictions, Appellant was statutorily mandated to register for ten years as a sex offender under Megan’s Law. Appellant filed an appeal to the Superior Court, arguing that the evidence was insufficient as a matter of law to sustain his conviction, because his offer of a ride to the children, by itself, did not constitute a “lure” or an attempt to “lure,” given that he did not offer the children any enticement to get into his car, nor did he command or otherwise threaten them. Appellant also argued that he had no ill intent in offering the children a ride, but, rather, was merely acting as a “disabled Good Samaritan.” After careful review, the Supreme Court concluded that an attempt to “lure” does not include the action of simply extending an offer of an automobile ride to a child, when it is unaccompanied by any other enticement or inducement for the child to enter the motor vehicle. Consequently, the Court reversed Appellant's conviction for attempted luring. View "Pennsylvania v. Hart" on Justia Law

Appellant Michael Travaglia appealed his death sentence imposed by the Westmoreland County Court of Common Pleas following a penalty hearing held pursuant to a grant of federal habeas corpus relief. Appellant was convicted in the shooting death of an Apollo police officer in 1980. Prior to the officer's homicide, state police received information indicating that Appellant was involved in a number of armed robberies and killings in Pittsburgh and surrounding counties. Appellant would later give a statement to police implicating himself in the killing of the officer and several others. Following the denial of his post-sentence motions Appellant appealed to the Supreme Court where he raised eighteen alleged errors in his penalty hearing. The Supreme Court took each issue in turn and ultimately affirmed Appellant's death sentence. View "Pennsylvania v. Travaglia" on Justia Law

Sean Pearce was bicycling along a road when he collided with a construction barrel and fell into the road. At least two vehicles, one driven by Appellee Gregory Wisneski, subsequently fatally struck Pearce. Appellee later admitted driving along the road when, initially thinking he hit a speed bump, he looked in his mirror and saw a body in the road. Appellee did not stop at the scene. The Commonwealth charged Appellee with failing to stop at an accident, failing to comply with a duty to give information and render aid, and failing to immediately notify the police. Appellee filed a habeas petition seeking dismissal of the charges, arguing the Commonwealth could not prove Pearce was alive when Appellee struck him. The trial court concluded that the statutes required the victim to be alive at the time of the accident, reasoning that "once a victim of an accident is dead, the accident concludes that the statutes cannot apply to vehicles that later come upon the scene." A divided Superior Court affirmed the trial court's dismissal of the information against Appellee. Upon review, the Supreme Court found that "a person does not turn into mere property upon their death, certainly not for purposes of a driver's obligations under the Vehicle Code. We find, therefore, the term 'resulting in injury' must include causing harm or damage to the body of a human, whether deceased or not. To find otherwise would defeat the legislative scheme, and would be offensive to our notions of the value of the person." The Court reversed the Superior Court and remanded the case for further proceedings. View "Pennsylvania v. Wisneski" on Justia Law