Justia Pennsylvania Supreme Court Opinion Summaries

In 2012, George Thomas Shifflett was charged with driving under the influence (DUI) and accepted into an Accelerated Rehabilitative Disposition (ARD) program. In 2022, Shifflett was involved in another DUI incident and was charged as a second-time offender based on his previous ARD acceptance. Shifflett pled guilty to the 2022 DUI but contested the use of his 2012 ARD as a prior offense for sentencing purposes, arguing it was unconstitutional under Alleyne v. United States.The Adams County Court of Common Pleas granted Shifflett's motion to exclude evidence of his 2012 ARD and sentenced him as a first-time offender. The Commonwealth appealed, and the Superior Court vacated the sentence, remanding for resentencing as a second-time offender, citing recent Superior Court decisions that overruled Commonwealth v. Chichkin, which had held that using ARD as a prior offense for sentencing was unconstitutional.The Supreme Court of Pennsylvania reviewed the case to determine if considering Shifflett's ARD as a prior offense for sentencing violated Alleyne. The Court held that ARD does not equate to a conviction because it lacks the procedural safeguards of a criminal trial, such as the right to a jury trial and the requirement of proof beyond a reasonable doubt. Therefore, using ARD as a prior offense for sentencing enhancement is unconstitutional under Alleyne.The Court concluded that Section 3806 of the Motor Vehicle Code, which includes ARD in the definition of a prior offense, is facially unconstitutional to the extent it allows ARD to be used for sentencing enhancement. The Court reversed the Superior Court's order and remanded the case for reinstatement of Shifflett's original sentence as a first-time offender. View "Commonwealth v. Shifflett" on Justia Law

On December 18, 2018, police responded to a report of check fraud at a bank involving two suspects. One suspect exited the bank and approached a Kia Soul before returning inside. Police located the vehicle with Rasheed Muhammad in the driver’s seat. Upon approaching, the officer detected marijuana and observed Muhammad searching the car’s center console and other areas. Muhammad provided a rental agreement for the car, which was in his name. After backup arrived, Muhammad was asked to exit the vehicle, and a search revealed a loaded firearm in the center console. Muhammad did not have a license to carry a firearm and was arrested after attempting to flee.The Delaware County Court of Common Pleas convicted Muhammad of carrying a firearm without a license and resisting arrest. Muhammad’s motion for acquittal was denied, and he was sentenced to 3 ½ to 7 years in prison for the firearm charge, followed by 2 years of probation for resisting arrest. The Superior Court affirmed the judgment, finding sufficient evidence to support the conviction based on the circumstances, including Muhammad’s proximity to the firearm and his behavior indicating knowledge and intent to conceal it.The Supreme Court of Pennsylvania reviewed whether the jury’s negative answer to a special interrogatory about Muhammad’s possession and control of the firearm rendered the evidence insufficient for his conviction. The court found no conflict between the jury’s answer and the conviction, noting that the interrogatory’s conjunctive phrasing did not negate the elements required for carrying a firearm without a license. The court affirmed the Superior Court’s order, upholding Muhammad’s judgment of sentence. View "Commonwealth v. Muhammad" on Justia Law

In this case, the appellant, Christopher Lynn Johnson, was convicted of first-degree murder and related offenses for the shooting death of Officer David Grove, a Deputy Wildlife Conservation Officer. On the night of November 11, 2010, Officer Grove encountered Johnson and his friend Ryan Laumann spotlighting deer near Gettysburg National Military Park. After stopping Johnson's vehicle, a confrontation ensued, during which Johnson shot Officer Grove multiple times, resulting in his death. Johnson fled the scene but was apprehended the following morning.The Court of Common Pleas of Adams County denied Johnson's petition for relief from his death sentence under the Post Conviction Relief Act (PCRA). Johnson raised multiple claims, including ineffective assistance of counsel, Brady violations, and improper victim impact evidence. The PCRA court held a five-day evidentiary hearing and ultimately found no merit in Johnson's claims. The court determined that Johnson failed to demonstrate prejudice from his counsel's actions and that there was no evidence of an agreement between the Commonwealth and Laumann regarding his testimony.The Supreme Court of Pennsylvania reviewed the case and affirmed the PCRA court's decision. The court found that Johnson's claims of ineffective assistance of counsel lacked merit, as his counsel conducted a thorough investigation and presented a robust mitigation defense during the penalty phase. The court also concluded that Johnson failed to prove any Brady or Napue violations, as there was no agreement between the Commonwealth and Laumann. Additionally, the court held that the victim impact evidence presented was permissible and did not violate Johnson's constitutional rights. Finally, the court determined that the cumulative effect of the alleged errors did not warrant relief. View "Commonwealth v. Johnson" on Justia Law

Keith Lamar Foster was interviewed by Detective Bryan Sellers regarding a sexual assault case. Foster voluntarily went to the police station, was not restrained, and was allowed to use his cell phone. During the interview, Detective Sellers told Foster he was not a suspect, despite having obtained a search warrant for Foster’s DNA. Foster provided a DNA sample, which later matched the DNA found on the victim, leading to his arrest and charges of rape and sexual assault.The Court of Common Pleas of Allegheny County granted Foster’s motion to suppress his statements, ruling that the detective’s misrepresentation rendered Foster’s statement involuntary. The court found that the detective’s statement deprived Foster of his ability to make a free and unconstrained choice to undergo the interview.The Superior Court of Pennsylvania reversed the suppression order, concluding that under the totality of the circumstances, Foster’s statement was voluntary. The court noted that Foster was not in custody, the interview was non-coercive, and Foster voluntarily provided his DNA sample.The Supreme Court of Pennsylvania affirmed the Superior Court’s decision. The court held that a misrepresentation by police that an interviewee is not a suspect does not per se render a statement involuntary under the Fifth Amendment. The court emphasized that the totality of the circumstances test remains the proper standard for determining voluntariness. The court found that Foster’s statement was voluntary, considering the non-coercive nature of the interview, Foster’s voluntary presence, and his consent to provide a DNA sample. View "Commonwealth v. Foster" on Justia Law

Dr. Omar Almusa, a licensed medical physician and surgeon in Pennsylvania, unlawfully distributed hydrocodone between 2014 and 2018. He pleaded guilty to unlawful dispensing and distributing a controlled substance, conspiracy to distribute, and health care fraud. In 2019, he was sentenced to 24 months in prison followed by three years of supervised release. Consequently, the State Board of Medicine automatically suspended his medical license for at least ten years, effective August 15, 2019.Almusa did not appeal the suspension. In 2020, the General Assembly enacted Act 53, redefining how licensing boards consider criminal offenses, specifying that only drug trafficking offenses (involving at least 100 grams of a controlled substance) warrant automatic suspension. Almusa's offense did not meet this threshold. In 2021, Almusa petitioned for reinstatement of his license, arguing that Act 53 should apply to his case, allowing him to seek reinstatement without waiting ten years.The Board denied his petition, stating that Act 53 did not apply retroactively to suspensions imposed before its enactment. The Commonwealth Court affirmed the Board's decision, interpreting the suspension and reinstatement as a single action requiring a ten-year suspension period.The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision. It held that automatic suspension and reinstatement are separate actions under the Medical Practice Act. The Court found that Act 53, effective December 28, 2020, applies to reinstatement proceedings initiated after this date. Since Almusa's offense did not qualify as drug trafficking under Act 53, the ten-year waiting period did not apply to his reinstatement petition. The Court concluded that Almusa was entitled to have his reinstatement petition considered under the new law. View "Almusa v. State Board of Medicine" on Justia Law

In 2007, Richard Roland Laird was sentenced to death following his retrial for first-degree murder, having originally been convicted and sentenced to death in 1988 for the same offense. Laird's most recent appeal challenges the denial of his latest Post Conviction Relief Act (PCRA) petition as untimely. He requested the Pennsylvania Supreme Court to create an equitable exception to the PCRA’s time-bar, citing the decision in Commonwealth v. Bradley, and also argued that Article 7 of the International Covenant on Civil and Political Rights (ICCPR) precluded the dismissal of his petition as untimely.The Court of Common Pleas of Bucks County denied Laird’s PCRA petition, finding it untimely and not meeting any statutory exceptions. The court also rejected Laird’s claims on the merits, including ineffective assistance of counsel (IAC) claims and an illegal sentencing claim. Laird’s appeal to the Pennsylvania Supreme Court followed.The Pennsylvania Supreme Court affirmed the lower court’s decision, holding that Bradley did not establish an equitable exception to the PCRA’s time-bar and that its rationale could not be extended to create one. The court emphasized that the PCRA’s time limitations are jurisdictional and not subject to equitable principles. Additionally, the court held that the ICCPR could not be invoked to circumvent the PCRA’s timeliness requirements, reaffirming that exceptions to the PCRA’s time-bar are strictly limited to those set forth in the statute.Thus, the Pennsylvania Supreme Court affirmed the order denying Laird’s PCRA petition as untimely, concluding that neither Bradley nor the ICCPR provided a basis to bypass the PCRA’s jurisdictional time-bar. View "Commonwealth v. Laird" on Justia Law

A police detective was charged with multiple criminal offenses, including unsworn falsification to authorities, tampering with or fabricating physical evidence, tampering with public records or information, and obstructing administration of law or other governmental function. The charges stemmed from allegations that the detective assisted his cousin in stalking a woman and attempted to cover up his misconduct by using police databases to obtain her information and then lying about it during an internal affairs investigation.The Municipal Court of Philadelphia dismissed the charges against the detective for lack of evidence. The Commonwealth refiled the charges, but the Court of Common Pleas of Philadelphia County also dismissed them, concluding that the Commonwealth failed to establish a prima facie case. The Superior Court of Pennsylvania affirmed the dismissal, agreeing that the evidence was insufficient to support the charges.The Supreme Court of Pennsylvania reviewed the case and reversed the Superior Court's decision. The Court held that the Commonwealth had presented sufficient evidence to establish a prima facie case for each of the charges. The Court found that the detective's actions, including his false statements during the internal affairs investigation and the suspicious addition of a second folder to the homicide file, supported the charges. The Court emphasized that at the preliminary hearing stage, the evidence must be viewed in the light most favorable to the Commonwealth, and all reasonable inferences must be drawn in its favor. The case was remanded for further proceedings. View "Commonwealth v. Williams" on Justia Law

William Roberts was convicted of statutory sexual assault, sexual assault, corruption of the morals of a minor, and indecent assault in 2005. He was sentenced to one and a half to three years in prison and required to register as a sexual offender for life under Megan’s Law III. Roberts complied with his registration obligations until 2019 but failed to report in 2020. The Pennsylvania State Police (PSP) discovered that Roberts no longer lived at his registered address and had not updated his information, leading to his arrest and charges for failing to comply with registration requirements.The Court of Common Pleas of Fayette County convicted Roberts of two counts of failure to comply with registration requirements and sentenced him to five to ten years in prison. Roberts appealed, arguing that the Commonwealth failed to prove he knew he was required to register. The Superior Court affirmed the conviction, holding that the crime occurred when Roberts knowingly failed to register or verify his residence, regardless of whether he knew he was required to do so.The Supreme Court of Pennsylvania reviewed the case to determine if the Commonwealth must prove that a sexual offender knew of their registration obligations to convict them of failure to comply. The Court held that the Commonwealth must prove the offender knew of their SORNA obligations. However, the Court found sufficient evidence that Roberts knew of his lifetime registration requirement, as he had signed forms acknowledging this multiple times. Thus, the Supreme Court affirmed the judgment of sentence. View "Commonwealth v. Roberts" on Justia Law

On May 8, 2020, Sergeant Aaron Scott and Officer Samuel Greco of the Frazer Township Police Department responded to a rollover vehicle accident. They found Jarren Crosby and a female companion near the overturned vehicle. Crosby admitted to driving, and the officers detected signs of marijuana use. Crosby was unsteady and had slurred speech. When the officers detained him for a DUI investigation, Crosby became agitated and resisted arrest. Officer Greco attempted to handcuff Crosby, who resisted by pulling away and screaming. Greco then tackled Crosby and used a taser to subdue him. Crosby was charged with multiple offenses, including DUI and resisting arrest.The Court of Common Pleas of Allegheny County convicted Crosby of DUI, resisting arrest, and careless driving, while acquitting him of other charges. Crosby was sentenced to four days in the DUI Alternative to Jail Program and fifteen months’ probation. Crosby’s post-sentence motions were denied, and he appealed, challenging the sufficiency of the evidence for his resisting arrest conviction.The Superior Court of Pennsylvania affirmed the trial court’s judgment, holding that the evidence was sufficient to support Crosby’s conviction for resisting arrest. The court noted that Crosby’s resistance required substantial force to overcome, as Officer Greco had to tackle him and use a taser.The Supreme Court of Pennsylvania reviewed the case and affirmed the Superior Court’s decision. The court clarified that the offense of resisting arrest under the second variant of the statute involves the defendant employing means that justify or require substantial force to overcome the resistance. The court held that Officer Greco’s tackle of Crosby constituted substantial force, and thus, the evidence was sufficient to support Crosby’s conviction for resisting arrest. The judgment of the Superior Court was affirmed, and the case was remanded to correct a scrivener’s error in the sentencing order. View "Commonwealth v. Crosby" on Justia Law

Derek Murchison was convicted of first-degree murder for the strangulation of Linda Willis on October 5, 2001, and sentenced to life in prison without parole. Murchison later sought post-conviction DNA testing of items found at the crime scene, arguing that the new DNA results constituted after-discovered evidence warranting a new trial.The Philadelphia County Court of Common Pleas dismissed Murchison's petition, and the Superior Court affirmed. The PCRA court found that the new DNA evidence was cumulative and would not likely compel a different verdict. The court noted that the jury had already been informed that Murchison's DNA was not found at the crime scene and still convicted him based on witness testimony and his confessions.The Supreme Court of Pennsylvania reviewed the case to determine if the lower courts applied the correct legal standard for after-discovered evidence claims based on post-conviction DNA testing. The court held that the same standard applies to all after-discovered evidence claims, including DNA evidence. The court concluded that the new DNA evidence did not establish Murchison's actual innocence and was not likely to result in a different verdict. The court affirmed the lower courts' decisions, emphasizing that the conviction was based on substantial witness testimony and Murchison's confessions, which were not undermined by the new DNA evidence. View "Commonwealth v. Murchison" on Justia Law