Justia Pennsylvania Supreme Court Opinion Summaries

Appellants Dawn Pyeritz sued the Commonwealth, the Pennsylvania State police and several of its police officers for the destruction of her personal property, speficially "a black nylon tree stand safety harness, or belt, that allegedly was crucial evidence in a separate civil action." The police seized this item during a criminal investigation of a suspicious death. A trooper agreed to retain the belt in the custody of the police, apparently for a longer time than permitted by internal police regulations. The belt was destroyed before Appellants' counsel asked for its return. The trial court granted summary judgment to the Appellees, which the Commonwealth Court affirmed. The Commonwealth Court held that no cause of action exists against a third party – someone other than the original alleged tortfeasor – for negligent spoliation of evidence. The Supreme Court granted review, and now holds that Pennsylvania law does not recognize a cause of action for negligent spoliation of evidence. View "Pyeritz v. Pennsylvania" on Justia Law

The issue before the Supreme Court was whether acceptance into an Accelerated Rehabilitative Disposition (ARD) program following a second charge of driving under the influence of alcohol (DUI) constituted a DUI violation and thus triggers the requirement for installation of an ignition interlock system as a condition of restoring a revoked driver's license. In 1998, Appellee John Whalen was convicted of DUI in Florida. Nine years later, Appellee was again arrested for DUI, this time in Pennsylvania. The trial court admitted Appellee into an ARD program after expressly making a determination that Appellee’s 1998 Florida DUI conviction did not present a bar to his entry into this program. Appellee successfully completed his ARD program. Pursuant to one provision of the ARD program, Appellee’s driver’s license was suspended for a period of sixty days, with the added condition that the ignition interlock be installed on his vehicle. Appellee appealed the ignition interlock requirement to the court of common pleas, arguing that the Department had no authority to impose this requirement in his case because ARD was not an adjudication of guilt. The Commonweath Court affirmed the DOT's decision. Upon reivew, the Supreme Court determined that the Commonwealth Court erred in its interpretation of the relevant statutory provisions when it concluded that acceptance into ARD did not establish a DUI violation. Accordingly, the Supreme Court reversed and remanded the case for further proceedings. View "Whalen v. Penna. Dept. of Trans." on Justia Law

Appellant David Chmiel challenged the dismissal of his petition for post conviction relief (pursuant to the Post Conviction Relief Act, 'PCRA'). Appellant was convicted on three counts of first-degree murder in 2002 and sentenced to death. Following his unsuccessful post-sentence motion that asserted forty alleged errors and eight claims of ineffectiveness of trial counsel, Appellant filed a timely pro se PCRA petition. The PCRA court denied Appellant’s request for PCRA relief in a detailed and extensive memorandum opinion and order filed in early 2009. This appeal followed, wherein Appellant stated twelve issues for review. In its own extensive opinion, the Supreme Court found that none of Appellant's assertions had any "arguable merit." The Court affirmed the PCRA court's order dismissing his claims. View "Pennsylvania v. Chmiel" on Justia Law

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