Justia Pennsylvania Supreme Court Opinion Summaries

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

A defendant was arrested on drug charges and initially held on high bail, which was later reduced. A bail bondsman posted the reduced bail, agreeing to be liable if the defendant failed to appear in court. The court scheduled a pretrial conference, but due to administrative errors, the defendant and his counsel were misinformed about the date. As a result, they missed the proceeding, leading the trial court to issue a bench warrant and revoke bail. Days later, when the defendant appeared for what he believed was the correct date, the court vacated the bench warrant and reinstated bail, relying on the defense counsel’s oral representation that the bondsman consented to continue as surety, but did not obtain written consent.Months later, the defendant failed to appear for trial, resulting in another bail revocation and notice of intent to forfeit the bond. The bondsman, after being notified of the impending forfeiture, filed a petition to strike or set aside the forfeiture, arguing that the court had failed to obtain his written consent when bail was previously reinstated. The Cumberland County Court of Common Pleas denied the petition. The Superior Court of Pennsylvania affirmed, reasoning that written consent was not required because the initial bail revocation was due to court error, not the defendant’s fault.The Supreme Court of Pennsylvania reviewed the case to determine whether the statutory requirement for written consent from a bail bondsman applies when bail is reinstated after a revocation caused by court error. The court held that the statute requires written consent from the bail bondsman whenever bail is reinstated after a defendant’s failure to appear, regardless of whether the failure was due to a breakdown in court administration. However, the court found that the bondsman was not entitled to relief because he failed to timely appeal the order reinstating bail. The Supreme Court affirmed the Superior Court’s result, but on different grounds. View "Commonwealth v. Rondon" on Justia Law

A woman, identified as the victim, lived with her mother and infant sister. The mother’s boyfriend, the appellant, would babysit the children at night. The victim testified that, starting at age 10, the appellant repeatedly entered her bedroom and sexually assaulted her. She disclosed the abuse to family members and a doctor, and later to a teacher, which led to police involvement. The appellant was charged with multiple sexual offenses, including rape of a child and related crimes.Before trial in the Court of Common Pleas of Allegheny County, the Commonwealth proposed a voir dire question to potential jurors, asking if they could follow the legal principle that the testimony of an alleged victim alone, if believed, is sufficient to convict in a sexual assault case. The appellant objected, arguing the question was improper and misstated the law. The trial court denied the objection, and the jury convicted the appellant on all charges, resulting in a lengthy prison sentence. The appellant’s post-sentence motion was denied, and he appealed to the Superior Court of Pennsylvania, arguing, among other things, that the voir dire question was improper. The Superior Court affirmed the judgment, finding the question proper and consistent with Pennsylvania law and jury instructions.The Supreme Court of Pennsylvania reviewed whether the trial court erred in allowing the voir dire question. The Court held that the trial court did not abuse its discretion. It found the question was designed to ensure jurors could follow the law that a victim’s uncorroborated testimony, if believed, can be sufficient for conviction in sexual assault cases. The Court concluded that such a question is permissible to identify jurors with fixed beliefs contrary to this legal principle. The judgment of sentence was affirmed. View "Commonwealth v. Walker" on Justia Law

A police officer observed a vehicle committing multiple traffic violations and initiated a stop. The officer discovered the vehicle was registered to someone other than the driver, George Anderson, and that Anderson's license was suspended. During the stop, the officer smelled marijuana and observed Anderson acting nervously. A protective search revealed a firearm and marijuana in the vehicle. Anderson was arrested and charged with various offenses, including firearm and drug possession.The Delaware County Court of Common Pleas denied Anderson's motion to suppress the evidence found in the vehicle, ruling that Anderson did not have a reasonable expectation of privacy in the car because it was not registered to him. Anderson was convicted of carrying a firearm without a license and sentenced to 42 to 84 months in prison. The Superior Court affirmed the trial court's decision, agreeing that Anderson failed to establish a reasonable expectation of privacy in the vehicle.The Supreme Court of Pennsylvania reviewed the case to determine whether the Commonwealth met its initial burden of production to show Anderson lacked a reasonable expectation of privacy by presenting evidence that the car was registered to someone else. The court held that the mere fact that the vehicle was registered to another person was insufficient to meet the Commonwealth's burden. The court emphasized that ownership is not a prerequisite for a reasonable expectation of privacy and that lawful possession or control can also establish such an expectation. The court reversed the Superior Court's decision and remanded the case for further proceedings to consider the totality of the circumstances and whether the Commonwealth met its burden based on all the evidence presented. View "Commonwealth v. Anderson" on Justia Law

In 2012, the appellant was charged with DUI and resolved the charge through acceptance into an Accelerated Rehabilitative Disposition (ARD) program. In 2020, he was again charged with DUI and convicted based on a guilty plea. The Pennsylvania Department of Transportation (PennDOT) received notice of his conviction and suspended his license for one year under Section 3804(e) of the Vehicle Code, which mandates a suspension for DUI convictions unless the individual has no prior offenses, including ARD acceptances within the past ten years.The appellant appealed the suspension to the Cumberland County Court of Common Pleas, which upheld the suspension despite the Superior Court's ruling in Commonwealth v. Chichkin, which disapproved of enhanced criminal sentencing based on an earlier ARD. The county court reasoned that the license suspension was a civil penalty and did not implicate the constitutional safeguards applicable in criminal matters. The Commonwealth Court affirmed this decision, agreeing that the suspension was a civil consequence and should be upheld as long as PennDOT acted in accordance with the law.The Supreme Court of Pennsylvania reviewed the case to determine whether the license suspension violated due process, given that the appellant's prior ARD acceptance was not a criminal conviction. The court held that the suspension did not violate due process. It reasoned that the suspension was based on the 2020 DUI conviction, not the prior ARD acceptance, and that the legislative scheme was rationally related to the state's interest in deterring drunk driving and ensuring public safety. The court affirmed the Commonwealth Court's order, upholding the one-year license suspension. View "Ferguson v. Dept. of Transportation" on Justia Law

In this case, the appellant, Willie James Hardy, was convicted of first-degree murder in 1993 and again in 1996 after being granted a new trial. Hardy has consistently maintained his innocence. In 2020, Hardy filed a petition for post-conviction DNA testing under Pennsylvania's Section 9543.1, seeking to test evidence from his case using modern DNA technology that was not available at the time of his trials. The evidence against Hardy was circumstantial, and previous DNA testing excluded him as a contributor.The Court of Common Pleas of Erie County denied Hardy's petition, reasoning that the request was untimely based on the precedent set by Commonwealth v. Edmiston, and that further testing would not provide substantially more accurate or probative results. The Superior Court affirmed this decision, emphasizing the delay in Hardy's request and the strength of the circumstantial evidence against him.The Supreme Court of Pennsylvania reviewed the case, focusing on three main issues: the timeliness of Hardy's request, the applicability of Section 9543.1(a)(2) regarding previously tested and untested evidence, and whether Hardy presented a prima facie case that DNA testing would establish his actual innocence. The court noted that the 2018 amendments to Section 9543.1 allow for DNA testing "at any time" and authorize retesting with newer technology.The Supreme Court held that Hardy's petition was timely, as the statute permits requests for DNA testing at any time and there was no indication that Hardy's request was intended to cause delay. The court also found that the lower courts erred in their interpretation of Section 9543.1(a)(2), as the statute allows for retesting with newer technology and does not preclude testing of previously untested evidence. Finally, the court concluded that Hardy met the prima facie burden by demonstrating a reasonable possibility that DNA testing could produce exculpatory evidence establishing his actual innocence.The Supreme Court reversed the Superior Court's order and remanded the case for further proceedings consistent with its opinion. View "Commonwealth v. Hardy" on Justia Law