Justia Pennsylvania Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Commonwealth v. Murchison
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
Posted in:
Criminal Law
Commonwealth v. Saunders
On November 18, 2020, Officer Matthew Ibbotson and his partner stopped a silver Honda with heavily tinted windows in a high-crime area of Philadelphia for traffic violations. The driver, Omar Saunders, made suspicious movements, and Officer Ibbotson saw the handle of a gun under the driver’s seat. Saunders admitted he did not have a permit for the gun, which was later found to be stolen. Saunders was arrested, and the gun was seized.The Court of Common Pleas of Philadelphia County denied Saunders’s motion to suppress the gun, ruling that the seizure was justified under the plain view doctrine and the automobile exception, which requires both probable cause and exigent circumstances. Saunders was convicted of firearms offenses and sentenced to three and a half to seven years in prison. The Superior Court affirmed the judgment, holding that the seizure was lawful under the plain view doctrine.The Supreme Court of Pennsylvania reviewed the case to determine the legality of the warrantless seizure. The court held that the seizure was constitutional under the plain view doctrine. It found that the police had a lawful vantage point, the incriminating nature of the gun was immediately apparent, and the police had a lawful right of access to the gun. The court emphasized that the unexpected development of probable cause during a lawful traffic stop justified the seizure without a warrant. Consequently, the court affirmed the Superior Court’s order upholding the denial of suppression of the firearm. View "Commonwealth v. Saunders" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Commonwealth v. Jones
Michael Jones was convicted of attempted murder and related charges after an incident where he and his codefendants, Syheed Wilson and Keirsten Carroll, were involved in a shooting of a cab driver, Alex Destin. Jones directed the cab driver and then shot him, while Wilson also shot the driver. The three were identified through surveillance footage and arrested. Wilson gave a statement to the police implicating Jones as the shooter.At trial, Jones objected to the admission of Wilson’s statement, arguing it violated the Sixth Amendment Confrontation Clause as established in Bruton v. United States. The trial court overruled the objection, and the jury was instructed to consider each defendant’s statement only against the one who made it. Jones was found guilty on all counts and sentenced to twenty to forty years in prison. The Superior Court affirmed the conviction, reasoning that the redacted statement, which referred to Jones as “my friend,” did not violate the Confrontation Clause because it did not explicitly name him and required linkage with other evidence to be incriminating.The Supreme Court of Pennsylvania reviewed the case, focusing on whether the admission of Wilson’s redacted statement violated Bruton. The court noted that the statement, though redacted to refer to Jones as “my friend,” still directly incriminated him by describing him in a way that the jury could easily identify him, especially since the jury was shown surveillance footage and still images identifying Jones. The court concluded that the statement violated Bruton’s prohibition against admitting a non-testifying codefendant’s confession that directly implicates the defendant.The Supreme Court of Pennsylvania vacated the Superior Court’s order and remanded the case for the Superior Court to determine whether the Bruton violation amounted to harmless error. View "Commonwealth v. Jones" on Justia Law
Posted in:
Constitutional Law, Criminal Law
In Re: The Thirtieth County Investigating Grand Jury
The case involves a petition challenging the public release of a grand jury report by the 30th County Investigating Grand Jury. The petitioner argued that the report did not meet the statutory definition of an "investigatory grand jury report" under the Investigatory Grand Jury Act (IGJA) and that the supervising judge erred in ordering its release. The petitioner also contended that the report's criticism of named, unindicted individuals violated their due process rights and the fundamental right to reputation under the Pennsylvania Constitution.The Philadelphia County Court of Common Pleas initially accepted the report and ordered its public release. The supervising judge provided notice and an opportunity to respond to some, but not all, named, unindicted individuals criticized in the report. The petitioner, along with others, sought to have the report permanently sealed or redacted. The supervising judge made some redactions but ultimately ordered the report to be unsealed.The Supreme Court of Pennsylvania reviewed the case and concluded that the report did not satisfy the IGJA's definition of an "investigatory grand jury report" because it neither related to organized crime or public corruption nor proposed recommendations for legislative, executive, or administrative action in the public interest. The court found that the report focused on punishing specific individuals and providing answers to the deceased-accused's family, rather than addressing broader public concerns.The court also determined that due process requires notice and an opportunity to respond for all named, unindicted individuals criticized in a grand jury report. The supervising judge's failure to provide such notice to all criticized individuals was deemed an error. Consequently, the Supreme Court vacated the supervising judge's order and remanded the case with instructions to permanently seal the report. View "In Re: The Thirtieth County Investigating Grand Jury" on Justia Law
Commonwealth v. Smith
Lisa Smith, the appellant, lived with her boyfriend, Keiff King, and her four-year-old son, Tahjir, in a home in Abington Township, Pennsylvania. On January 22, 2018, after Tahjir spilled cereal, he was subjected to severe punishment by Smith and King, including being forced to hold difficult positions and being beaten. Tahjir was also placed in a hot shower, resulting in severe burns. Later, when Tahjir showed signs of severe distress, Smith and King delayed seeking medical help. Eventually, Smith called 911, but Tahjir was pronounced dead at the hospital. An autopsy revealed that Tahjir died from "crush syndrome" due to severe beatings and burns.Smith and King were charged with first-degree murder, endangering the welfare of a child, and criminal conspiracy. Smith's motion to suppress her statements to the police was partially granted, excluding statements made before receiving Miranda warnings. At trial, King's redacted statement, which replaced Smith's name with feminine pronouns, was admitted. The trial court instructed the jury to consider King's statement only against him. Both Smith and King were convicted, and Smith was sentenced to life in prison without parole, plus additional years.The Supreme Court of Pennsylvania reviewed whether Smith's Sixth Amendment right to confrontation was violated by admitting King's redacted statement. The court held that there was no violation, as the redacted statement did not directly or powerfully implicate Smith in the crime. The court emphasized that the statement did not identify Smith as a participant in the abuse and that the jury was properly instructed to consider the statement only against King. Consequently, the court affirmed the Superior Court's decision, upholding Smith's conviction and sentence. View "Commonwealth v. Smith" on Justia Law
Posted in:
Civil Rights, Criminal Law
Commonwealth v. Lear
The case involves Jason Andrew Lear, who faced criminal charges for theft and assault in Montgomery County, Pennsylvania. The charges were filed in May, June, and July 2020. Due to the COVID-19 pandemic, the Montgomery County Court of Common Pleas suspended criminal trials and implemented strict protocols, delaying Lear's trial. His trial was eventually scheduled for November 1, 2021, well beyond the 365-day limit set by Pennsylvania Rule of Criminal Procedure 600.The Montgomery County Court of Common Pleas denied Lear's motion to dismiss based on Rule 600, reasoning that the delay was due to the judicial emergency caused by the pandemic. Lear was convicted and sentenced to five to twelve years in prison. He appealed to the Superior Court, which vacated his sentence and remanded the case for a hearing to determine if the Commonwealth had acted with due diligence during the delay.The Supreme Court of Pennsylvania reviewed whether Rule 600 requires the Commonwealth to demonstrate due diligence during a judicial emergency. The Court held that the delays caused by the COVID-19 pandemic and related court closures do not fall under the "judicial delay" category requiring a due diligence assessment. Instead, these delays are considered "other periods of delay" under Rule 600(C)(1) and are excludable from the 365-day computation without assessing the Commonwealth's diligence. The Court reversed the Superior Court's decision, ruling that no Rule 600 violation occurred and no hearing was necessary. View "Commonwealth v. Lear" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Strunk
The case involves Michael L. Strunk, who was convicted of multiple sexual offenses against a minor, including unlawful contact with a minor. The victim testified that Strunk assaulted her on three separate occasions, each time while she pretended to be asleep. During these assaults, Strunk engaged in various forms of physical contact, such as fondling her and removing her clothing, but there was no evidence of verbal or non-verbal communication to facilitate the assaults.Strunk was convicted in the Dauphin County Court of Common Pleas and sentenced to an aggregate term of 17 to 35 years’ incarceration. He filed post-sentence motions challenging the weight and sufficiency of the evidence, which were denied. On appeal, the Superior Court affirmed the conviction, concluding that the physical contact beyond the assaults themselves was sufficient to establish a violation of Section 6318 of the Pennsylvania Crimes Code, which criminalizes unlawful contact with a minor.The Supreme Court of Pennsylvania reviewed the case and focused on whether the term "in contact with" under Section 6318 includes non-communicative conduct. The Court concluded that the statute is intended to criminalize communicative behavior aimed at facilitating sexual exploitation, not merely physical contact. The Court found that the Superior Court erred in its interpretation by equating physical contact with communication. Since there was no evidence that Strunk communicated with the victim to facilitate the assaults, the Supreme Court vacated his conviction for unlawful contact with a minor. This decision did not affect the aggregate sentence, as the sentence for this conviction was imposed concurrently with other sentences. View "Commonwealth v. Strunk" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Rivera
In this case, the appellant, Cletus Rivera, was convicted of first-degree murder and sentenced to death for the killing of Reading Police Officer Scott Wertz. The incident occurred when Officers Wertz and Eddinger, working in plainclothes, responded to a disturbance and gunfire in a parking lot. Rivera, identified as the shooter, was pursued by Officer Wertz, who was subsequently shot and killed by Rivera. Rivera claimed self-defense, stating he did not know Wertz was a police officer. The jury convicted Rivera, and the death sentence was imposed based on aggravating circumstances, including the victim being a peace officer on duty.Rivera's conviction and sentence were affirmed by the Pennsylvania Supreme Court in 2009, and his petition for a writ of certiorari was denied by the U.S. Supreme Court in 2010. Rivera's first Post Conviction Relief Act (PCRA) petition was also denied, with the Pennsylvania Supreme Court finding no merit in his claims, including ineffective assistance of counsel and Brady violations related to a jailhouse informant, Jason Ott.In 2017, Rivera filed a second PCRA petition, citing newly discovered evidence from federal court proceedings that allegedly supported his previous claims about Ott's credibility and the existence of an undisclosed agreement between Ott and the Commonwealth. The PCRA court denied this petition, concluding that the new evidence was not material to Rivera's guilt or punishment and that his trial counsel's performance did not prejudice the outcome.The Pennsylvania Supreme Court, currently reviewing the case, vacated the PCRA court's order and remanded the case for further analysis. The Court directed the PCRA court to independently determine whether Rivera's claims met the newly discovered facts or governmental interference exceptions to the PCRA's time bar and whether they complied with the filing requirements. The Supreme Court emphasized that jurisdictional issues must be independently assessed, regardless of the parties' agreement on the timeliness of the petition. View "Commonwealth v. Rivera" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Yard
In August 2021, Michael Yard’s infant son died from blunt-force trauma to the head while Yard was the sole caregiver. The child had also suffered broken ribs weeks earlier. Yard was charged with first-degree murder and other offenses in April 2022 and was denied bail by a Magisterial District Judge. At a preliminary hearing, evidence including an autopsy report and a 911 call was presented, and all charges were bound over to the Monroe County Court of Common Pleas.Yard petitioned for bail, citing a Pennsylvania Supreme Court decision, Commonwealth v. Talley, which established a unique standard of proof for denying bail under the state Constitution. The bail court initially set bail at $200,000 with conditions but later vacated this decision, interpreting Talley to require live testimony rather than a "cold record." The Superior Court vacated the bail order and remanded for further proceedings. Yard then filed for nominal bail under Rule 600, which was granted by the bail court, setting bail at $1.00 with conditions.The Commonwealth appealed, and the Pennsylvania Supreme Court assumed jurisdiction. The Court held that the proof/presumption limitation in Article I, Section 14 of the Pennsylvania Constitution does not apply to the life-offense exception to the right to bail. Therefore, when a defendant is charged with an offense carrying a maximum sentence of life imprisonment, the Constitution categorically precludes release on bail. The Court vacated the bail court’s order granting nominal bail and remanded for further proceedings consistent with this opinion. View "Commonwealth v. Yard" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Commonwealth v. Anderson
In this case, the appellant was convicted of two counts of first-degree murder, one count of first-degree murder of an unborn child, and two counts of endangering the welfare of children. The crimes occurred in July 2020, when the appellant fatally shot Sydney Parmalee and Kaylee Lyons. Sydney was found dead in an apartment with a gunshot wound to her head, and Kaylee was found dead under similar circumstances later that month. The appellant was the father of both women’s children and was present at the scenes of both murders. He initially claimed Sydney’s death was a suicide but later admitted to killing both women.The Court of Common Pleas of Cumberland County convicted the appellant and sentenced him to death for Kaylee’s murder, life imprisonment for Sydney’s murder, and life imprisonment for the murder of Kaylee’s unborn child. The jury found one aggravating circumstance for Kaylee’s murder, which was that the appellant had been convicted of another offense punishable by death (Sydney’s murder). The appellant’s post-sentence motion was denied, leading to this direct appeal.The Supreme Court of Pennsylvania reviewed the case and affirmed the judgment of sentence. The court found that the evidence was sufficient to support the convictions for first-degree murder, as the appellant used a deadly weapon on vital parts of the victims’ bodies, demonstrating malice and specific intent to kill. The court also upheld the conviction for endangering the welfare of a child, noting that the appellant left his son alone in the apartment after killing Kaylee.The court rejected the appellant’s argument that his spontaneous confession should have been suppressed, ruling that it was a voluntary statement not prompted by police questioning. The court also found no abuse of discretion in the trial court’s denial of a new trial based on the weight of the evidence. Finally, the court concluded that the death sentence was not the product of passion, prejudice, or any other arbitrary factor and was supported by the evidence of the aggravating circumstance. View "Commonwealth v. Anderson" on Justia Law
Posted in:
Criminal Law