Justia Pennsylvania Supreme Court Opinion Summaries

In this case, the defendant was convicted by a jury of third-degree murder in 2002 for the killing of a police officer. At trial, the prosecution presented several witnesses who implicated the defendant, including testimony from an individual who claimed to have observed the shooting and another who reported the defendant’s incriminating statements. The defense was precluded from introducing evidence suggesting that another individual, Tusweet Smith, may have been the perpetrator, including testimony about Smith’s alleged intent and confessions. Over the years, the defendant filed multiple post-conviction petitions, raising claims based on newly discovered evidence and recantations by key prosecution witnesses. These petitions were denied, primarily on timeliness grounds under Pennsylvania’s Post Conviction Relief Act (PCRA), which imposes a one-year filing limit unless specific exceptions are met.The Court of Common Pleas of Beaver County dismissed the defendant’s most recent PCRA petition, finding it untimely and holding that a third-party confession (specifically, Smith’s confession to another inmate, Dorsett) could not qualify as a newly discovered fact because it was deemed inadmissible hearsay. The Superior Court affirmed the dismissal regarding the third-party confession, relying on precedent that inadmissible hearsay cannot support the PCRA’s newly discovered facts exception. However, the Superior Court agreed that the defendant was entitled to an evidentiary hearing on separate statements and affidavits but not on the Dorsett/Smith confession.The Supreme Court of Pennsylvania reversed the Superior Court’s order as to the Dorsett/Smith statement. The Court held that a PCRA petitioner may establish the newly discovered facts exception with evidence that would be admissible at a PCRA hearing, and that a third-party confession to another person can serve as a newly discovered fact under the PCRA if properly pleaded. The Court remanded for an evidentiary hearing to allow the defendant to attempt to prove his allegations with admissible evidence. View "Commonwealth v. Brown" on Justia Law

In this case, the defendant was charged with raping three different women on three separate occasions in Philadelphia, spanning from 2011 to 2015. Each victim underwent a sexual assault examination, and DNA evidence was collected but did not initially match any known profiles. In December 2018, a DNA database search revealed that the same DNA profile was present in all three cases. This profile was subsequently identified as belonging to the defendant, who was then arrested and charged separately for each incident.The prosecution moved to consolidate the three cases for a joint jury trial, arguing that the assaults were sufficiently similar to be admissible under the common plan, scheme, or design exception to Pennsylvania’s rule against propensity evidence. The defendant objected, but the Philadelphia County Court of Common Pleas granted the consolidation and allowed the introduction of rape kit reports prepared by nurse examiners who did not testify at trial. The defendant was convicted on multiple counts, and the court imposed an aggregate sentence. On appeal, the Superior Court of Pennsylvania affirmed the convictions and the admission of the rape kit reports, finding the cases sufficiently similar for consolidation and the reports non-testimonial and admissible under hearsay exceptions.Upon review, the Supreme Court of Pennsylvania concluded that consolidation was improper under the current interpretation of the common plan, scheme, or design exception, holding that such consolidation is permissible only if the offenses are signature crimes or part of a common goal, neither of which applied here. Additionally, the court held that admitting the rape kit reports without the testimony of the nurse examiners violated the defendant’s right to confront witnesses under the Confrontation Clause. Accordingly, the Supreme Court of Pennsylvania vacated the judgment of sentence and remanded for further proceedings. View "Commonwealth v. Walker" on Justia Law

In this case, a woman named Annemarie Fitzpatrick drowned in Muddy Creek, Pennsylvania, while riding an ATV with her husband, Joseph Fitzpatrick. Initial investigations suggested an accidental death, but subsequent evidence—including a note written by Annemarie expressing fear of her husband, an email detailing marital problems, and findings from a forensic pathologist—raised suspicions of foul play. Additional evidence included Fitzpatrick’s extramarital affair, internet searches related to life insurance and polygraph laws, and testimony from an accident reconstructionist challenging Fitzpatrick’s account of the incident.After a jury convicted Fitzpatrick of first-degree murder and he was sentenced to life imprisonment, the York County Court of Common Pleas granted his post-sentence motion for acquittal, finding the evidence insufficient to prove homicide beyond a reasonable doubt. The trial court cited the equivocal expert testimony and the lack of definitive proof of an unlawful killing. On appeal, the Superior Court reversed the acquittal, reinstated Fitzpatrick’s conviction, and held that circumstantial evidence and expert testimony were sufficient for conviction. Later, during pre-trial proceedings for a retrial, the admissibility of expert testimony regarding the manner of death became a central issue. The trial court excluded an expert’s opinion on manner of death, finding it speculative and not held to a reasonable degree of medical certainty.The Supreme Court of Pennsylvania reviewed whether expert testimony regarding manner of death must meet the same admissibility standards as other expert opinions. The Court held that all expert opinions, including those on manner of death, must be stated to a reasonable degree of certainty to be admissible. The Court rejected the lower standard of “more likely than not” adopted by the Superior Court, reversed its order, and remanded for further proceedings, reaffirming the longstanding requirement for certainty in expert testimony. View "Commonwealth v. Fitzpatrick" on Justia Law

A woman was kidnapped and raped in her rural home after her husband left for work. The perpetrator bound, gagged, and blindfolded her, then drove her to another location where he assaulted her. After being released in a field, the victim contacted police, who collected DNA evidence but initially could not identify the assailant. Investigators suspected the crime was premeditated due to the remote location, timing, and other factors, and obtained a “reverse keyword search warrant” for Google records of searches related to the victim’s name and address. Google identified two searches for the victim’s address made just before the attack, both linked to the same IP address, which was traced to John Edward Kurtz. Surveillance and DNA from a discarded cigarette butt confirmed the match, and Kurtz confessed to this and other assaults.Kurtz moved to suppress the evidence from the Google search, arguing the search warrant lacked probable cause individualized to him and that his internet search records were protected by a reasonable expectation of privacy. The Northumberland County Court of Common Pleas denied the motion, and a jury found Kurtz guilty on all charges. He was sentenced to a lengthy prison term. On appeal, the Pennsylvania Superior Court affirmed, holding that Kurtz lacked an expectation of privacy in his Google search records or IP address, reasoning that he voluntarily provided this information to a third party and had agreed to Google’s privacy policy allowing cooperation with law enforcement.The Supreme Court of Pennsylvania reviewed whether individuals have a reasonable expectation of privacy in their unprotected internet search queries and IP addresses. The court held that the average user does not have such an expectation, as using a search engine like Google involves voluntarily providing information to a third party with clear notice that the information may be shared, including with law enforcement. The judgment below was affirmed. View "Commonwealth v. Kurtz" on Justia Law

Four police officers entered a Pittsburgh rowhouse searching for a missing person. Inside, Vincent Smith, the appellant, started a fire that endangered the officers, who escaped unharmed. Smith was rescued and treated for smoke inhalation. The bodies of two men, previously killed by Smith, were found in the residence. Smith admitted to the killings and to starting the fire in a suicide attempt. He was charged with two counts of voluntary manslaughter and four counts of arson endangering persons (AEP), one for each officer present.Smith pled guilty to all charges in the Allegheny County Court of Common Pleas. The trial court sentenced him to consecutive terms for each manslaughter and each AEP count, totaling 26 to 52 years. Smith challenged the legality of receiving multiple sentences for AEP based on a single act of arson that endangered multiple people. The trial court, relying on Commonwealth v. Frisbie, held that each endangered person constituted a separate unit of prosecution under the AEP statute.Smith appealed to the Superior Court of Pennsylvania, arguing that only one sentence for AEP should be imposed per arson, regardless of the number of people endangered. Initially, a panel vacated three AEP sentences, but after reargument, the en banc Superior Court affirmed the trial court, holding that the unit of prosecution was each endangered person.The Supreme Court of Pennsylvania reviewed the case to determine the correct unit of prosecution for AEP under 18 Pa.C.S. § 3301(a)(1)(i). The Court held that the unit of prosecution is each act of arson, not each person endangered. It found the statute ambiguous and applied the rule of lenity, strictly construing it in favor of the defendant. The Supreme Court reversed the Superior Court’s decision, vacated Smith’s sentence, and remanded for resentencing consistent with its holding. View "Commonwealth v. Smith" on Justia Law

The appellant was convicted of first-degree murder for killing his estranged wife’s 14-month-old son, as well as attempted murder and aggravated assault of his estranged wife’s roommate. The prosecution’s case relied heavily on the testimony of a police officer who witnessed the events. At trial, the appellant represented himself and claimed innocence, alleging a police cover-up. During jury selection, one juror initially indicated on a questionnaire that a family member had been charged with a crime, but then changed the answer to “no.” Decades later, the appellant’s counsel discovered that this juror’s nephew had, in fact, been charged with attempted murder of an infant before the trial, a fact not disclosed during voir dire.The Court of Common Pleas of Dauphin County dismissed the appellant’s third Post Conviction Relief Act (PCRA) petition as untimely, reasoning that the information about the juror’s nephew was available in a 2002 news article and thus not a “new fact.” The court concluded that the appellant failed to show why he could not have discovered this information earlier, and therefore did not meet the requirements for the previously unknown fact exception to the PCRA’s time bar.The Supreme Court of Pennsylvania reviewed the dismissal de novo. It held that the lower court erred by applying a presumption that the appellant knew of the juror’s family connection simply because the information was publicly available. The Supreme Court clarified that the relevant inquiry is whether the appellant actually knew or could have discovered the fact through reasonable diligence, not whether the information was in the public record. The Court vacated the order dismissing the petition and remanded for further proceedings, holding that the appellant was entitled to a hearing to establish whether he met the requirements for the newly discovered fact exception. View "Commonwealth v. Blakeney" on Justia Law

The case concerns an individual who was arrested twice for suspicion of driving under the influence (DUI) in Pennsylvania. The first arrest led to charges, while the second arrest did not result in charges until several months later. In the interim, the individual applied for admission to the county’s Accelerated Rehabilitative Disposition (ARD) program for the first DUI. The ARD application required disclosure of prior convictions, prior ARD participation, and any pending criminal charges, but did not ask about uncharged arrests. The applicant truthfully stated he had no pending charges at the time of the application.After the applicant was admitted to the ARD program, the Commonwealth learned of the second DUI charge and moved to revoke his ARD participation, arguing he violated program conditions by not disclosing the prior arrest. The Adams County Court of Common Pleas revoked his ARD participation, initially citing the new charges and later referencing “deception by omission.” The applicant was subsequently convicted and sentenced for the first DUI. The Pennsylvania Superior Court affirmed, reasoning that failing to disclose the second arrest, even if uncharged, undermined the spirit and intent of the ARD program, and relied on prior cases where omissions or misrepresentations justified ARD revocation.The Supreme Court of Pennsylvania reviewed the case and held that revocation of ARD participation must be based on violation of a specified condition of the program, not on implied conditions or the general “spirit” of the program. The Court found that the applicant answered all questions on the ARD application truthfully, as there were no pending charges at the time, and the application did not require disclosure of uncharged arrests. Therefore, the trial court erred in revoking ARD participation, and the Supreme Court reversed the Superior Court’s decision. View "Commonwealth v. Jenkins" on Justia Law

The appellant pleaded guilty in 2015 to driving under the influence and resisting arrest, receiving a sentence of incarceration followed by probation. While serving probation for this 2015 case, he was arrested in 2018 for aggravated assault. After his mother posted bail on the new charges, a probation detainer from the 2015 case kept him in custody. He later pleaded guilty to aggravated assault in the 2018 case and was sentenced to a term of imprisonment. The trial court did not credit him for all the time he spent in custody before sentencing, specifically the period he was held solely on the probation detainer after bail was posted in the 2018 case.The Lackawanna County Court of Common Pleas, acting as the PCRA court, granted partial relief by awarding credit only for the period after the detainer was lifted, reasoning that the earlier period of confinement was solely due to the probation detainer in the 2015 case, for which only a probationary sentence was ultimately imposed. The Pennsylvania Superior Court affirmed, holding that the appellant was not entitled to credit for time spent in custody on the probation detainer because no prison sentence was imposed in the 2015 case, and the time was not attributable to the new charges after bail was posted.The Supreme Court of Pennsylvania reviewed the statutory language of 42 Pa.C.S. § 9760(1) and held that a defendant is entitled to credit against a new prison sentence for all time spent in custody as a result of the conduct underlying the new charge, even if the confinement was due to a probation detainer from an earlier case, so long as the conduct leading to the detainer is the same as that underlying the new charge. The Court reversed the Superior Court’s order and remanded for further proceedings to determine if relief could still be awarded. View "Commonwealth v. Phillips" on Justia Law

The case concerns James Smith, who was charged with multiple counts of child sexual assault involving two minor victims, the daughters of a friend, in Philadelphia. Before trial, Smith requested that the jury panel be asked during voir dire whether they were more likely to believe the testimony of a child alleging sexual abuse because they did not believe a child could lie about such abuse. The trial court declined to ask this specific question but did inform jurors about the nature of the charges, asked about their ability to be impartial, and conducted individual voir dire regarding experiences with sexual assault or child abuse, dismissing several jurors for cause based on their responses.Smith was convicted on all counts, including rape of a child, unlawful contact with a minor, corruption of minors, involuntary deviate sexual intercourse with a child, and aggravated indecent assault of a person less than thirteen years of age. He appealed to the Superior Court of Pennsylvania, arguing that the trial court erred in refusing his proposed voir dire question and that the evidence was insufficient to support his convictions for unlawful contact with a minor. The Superior Court affirmed the trial court’s judgment, finding no error in the voir dire process and concluding that Smith’s communications with the victims met the statutory requirements for unlawful contact.On further appeal, the Supreme Court of Pennsylvania reviewed two issues: whether the trial court abused its discretion in refusing to ask the proposed voir dire question about bias toward child victim testimony, and whether the Superior Court had impermissibly expanded the scope of criminal liability under the unlawful contact statute. The Supreme Court held that, on the record presented, the trial court did not abuse its discretion in refusing the voir dire question. Regarding the unlawful contact conviction, the Supreme Court vacated the Superior Court’s judgment and remanded for reconsideration in light of its recent decision in Commonwealth v. Strunk, which clarified the scope of the relevant statute. View "Commonwealth v. Smith" on Justia Law

Police officers on patrol in Philadelphia observed a group of men on the 1200 block of West Dauphin Street who appeared to be gambling, an activity prohibited by city ordinance. As the officers approached, Anthony Lewis, who was among the group and carrying a black leather bag, made eye contact with one of the officers, appeared startled, and fled. The officers pursued Lewis, who was apprehended after discarding his bag over a fence. The bag was recovered and found to contain a loaded firearm, and DNA evidence later linked Lewis to the gun.Lewis moved to suppress the firearm, arguing that the police lacked reasonable suspicion to pursue him. At the suppression hearing in the Philadelphia County Court of Common Pleas, the Commonwealth presented testimony from the officers, who described the area as known for gambling, narcotics sales, and recent violent crimes. The trial court credited the officers’ testimony, found the area to be high in crime, and concluded that Lewis’s unprovoked flight in that context gave rise to reasonable suspicion. The court denied the suppression motion, and Lewis was subsequently convicted of several firearm offenses. The Superior Court of Pennsylvania affirmed, holding that the officers’ observations, combined with the high-crime nature of the area and Lewis’s flight, supported reasonable suspicion for the stop and that the firearm was not the product of coerced abandonment.The Supreme Court of Pennsylvania reviewed whether the evidence was sufficient to establish the area as high in crime and whether the firearm should have been suppressed. The court held that the Commonwealth bears the burden of proving an area is high in crime but declined to impose a rigid, multi-element test for such a designation. Instead, the court left the determination to the discretion of suppression courts, emphasizing that mere invocation of “high-crime area” is insufficient. The court affirmed the Superior Court’s order, holding that the evidence supported the finding of a high-crime area and that the police had reasonable suspicion to pursue Lewis. View "Commonwealth v. Lewis" on Justia Law