Justia Pennsylvania Supreme Court Opinion Summaries

Pennsylvania's current version of Megan's Law requires individuals convicted of kidnapping, indecent assault, or promoting prostitution to register for ten years following release from jail or probation. Persons convicted of two or more offenses subject to the ten-year registration must register for life. Allegheny County (the County) amended its code to add to the registration requirements: if a registrant moves to a "prohibited area" within the County, s/he will have 45 days to move out. Failure to move within the 45 days would constitute a separate offense. Appellee Charles Fross and several other parties were convicted sex offenders subjected to the County's new rule. They brought suit in federal court to challenge the new ordinance, arguing that the rule was preempted by the state Sentencing and Parole Codes, and asked the court to declare the ordinance invalid. The federal court certified the question of whether the County's ordinance was preempted by the Pennsylvania Prisons and Parole Code and/or by the Pennsylvania Sentencing Code to the Supreme Court. The County argued that the ordinance was a permissible exercise of its powers, and was valid. The Supreme Court found that the ordinance "impedes the accomplishments of the full objectives of the General Assembly, as expressed in the Sentencing and Parole Codes, and is . . . invalid pursuant to our conflict preemption doctrine."

Appellee Ronald Gibson challenged his sentence for the shooting deaths of a police officer and a bystander during a failed robbery attempt at a bar in Philadelphia. After multiple remands, Appellee argued to the Supreme Court that he received ineffective assistance of counsel that resulted in prejudice against him at trial. The appellate court concluded that Appelleeâs counsel was âderelictâ by failing to adequately investigate life-history or mental health mitigation evidence. The court concluded, however, that the trial court should have resolved certain questions that arose from evidentiary discrepancies. The Supreme Court performed an exhaustive review of the evidence presented at trial. While not diminishing Appelleeâs troubles, the Court found that the mitigating evidence Appellee sought to enter at trial was not enough to overcome the aggravating factors introduced at trial or to overturn the juryâs verdict. The Court held that Appelleeâs claim for ineffective assistance of counsel to be unfounded, and it affirmed Appelleeâs conviction and sentence.

Appellant Mark Spotz appealed the denial of his petition for collateral relief under the Commonwealthâs Post Conviction Relief Act (PCRA). While engaged in a three-day crime spree in early 1995, Appellant killed four people in four counties. He was tried separately for each homicide, and he was ultimately convicted of first-degree murder and given the death sentence. Since his conviction, Appellant has applied for and received judicial review of his convictions and sentence. Each time, Appellant has raised constitutional bases or trial and/or appellate court errors to seek the next review. The string of appeals ends for now with this case. Here, Appellant sought review of an order of the PCRA court that denied his petition for collateral relief relating to the death of Betty Amstutz in February, 1995. During the guilt phase of trial, Appellant appeared pro se and asserted an innocence defense. The jury found him guilty. He was assigned a public defender for the sentencing phase and was sentenced to death. Appellant appealed to the PCRA alleging errors at trial, ineffective assistance of counsel, and a host of other matters, all of which were denied. The Supreme Court engaged in an exhaustive review of Appellantâs case history dating back to the original trial in 1996, and found no errors that warranted the post-conviction relief Appellant sought. The Court affirmed the lower courtsâ decisions.