Justia Pennsylvania Supreme Court Opinion Summaries

In this matter, the trial court instructed the jury, prior to deliberations, that one of the prerequisites necessary to establish the crime of witness intimidation as a first-degree felony had been fulfilled. The Pennsylvania Supreme Court allowed appeal to consider whether that instruction violated the defendant’s right to a jury trial under the Sixth Amendment to the United States Constitution as interpreted in Apprendi v. New Jersey, 530 U.S. 466 (2000). The Supreme Court found that that the jury found Appellant’s conduct to have encompassed one or more aggravating factors as set forth in paragraph 18 Pa.C.S. 4952(b)(1); the trial court told the jury that, to return a guilty verdict, it would have to find one of the (b)(1) aggravators. That being the case, the verdict, when purged of the taint stemming from the erroneous instruction, established guilt on the witness-intimidation charge at the third-degree-felony level. The maximum prison sentence Appellant would have faced at that level was seven years. Because Appellant was sentenced to twelve years, for Apprendi purposes the sentence was greater than the otherwise-imposable statutory maximum. Judgment was reversed and remanded for further proceedings. View "Pennsylvania v. Dixon" on Justia Law

The victim in this case, Annemarie Fitzpatrick wrote a note in her day planner on the day before she died. The note read: “If something happens to me—JOE,” an apparent reference to her husband, Joseph Fitzpatrick, III. Both the trial court and the Superior Court held that Annemarie’s statement was admissible as an expression of her then-existing state of mind under Rule 803(3). The Pennsylvania Supreme Court concluded the statement was admitted in error, and that the error was not harmless. Hence, judgment was reversed, and the case remanded for a new trial. View "Pennsylvania v. Fitzpatrick III" on Justia Law

In this case of first impression, the Pennsylvania Supreme Court granted allocatur to determine whether Jack Satterfield raised a meritorious challenge to the legality of the sentences imposed on three counts of leaving the scene of an accident involving death or personal injury, stemming from a multi-vehicle crash that resulted in three fatalities. The Supreme Court concluded two of Satterfield’s three sentences were illegal. Accordingly, the Court reversed the order of the Superior Court, vacated the judgment of sentence, and remanded for resentencing. View "Pennsylvania v. Satterfield" on Justia Law

The Pennsylvania Supreme Court granted discretionary review in this case to determine whether the superior court properly determined language in the 2010 amendment to the corruption of minors statute, "in violation of Chapter 31," was an essential element of an offense under the statute. Upon review, the Supreme Court agreed with the superior court's assessment. And, because appellee James Baker-Myers was acquitted of all Chapter 31 sexual offenses charged in the indictment and submitted to the jury, the Supreme Court further agreed that, under these circumstances, appellee's conviction for third-degree felony corruption of minors, could not stand. View "Pennsylvania v. Baker-Myers" on Justia Law

The primary issue raised in this discretionary appeal was whether the trial court properly excluded evidence that two of Appellant Eric Rogers’ rape victims had a history of prostitution convictions, where Appellant’s defense included a contention that the encounters were consensual instances of prostitution. The Pennsylvania Supreme Court affirmed the superior court’s ruling insofar as it upheld the common pleas court’s denial of Appellant’s motion in limine, thereby excluding from trial any evidence concerning the alleged prostitution convictions of A.P. and M.H. The intermediate court’s order was vacated, however, to the extent it found Appellant’s weight-of-the-evidence claim waived, and the matter was remanded for a merits disposition of that claim. View "Pennsylvania v. Rogers" on Justia Law

In 2017, United States Marshalls went to the home of appellant Eric Yale’s mother (where Yale resided) to serve an arrest warrant on Larry Thompson. Officer Jeffrey Ference of the Wilkes-Barre Police Department assisted the Marshalls in serving the warrant. While searching the residence for Thompson, Officer Ference entered Yale’s bedroom, where he found Yale, soda bottles containing methamphetamine, and materials commonly used to produce methamphetamine, including lighter fluid, Drano, lithium batteries, and soda bottles with tubes coming out of them. Officer Ference found Thompson hiding in the closet in Yale’s bedroom. He took both Thompson and Yale into custody. After being read his Miranda rights, Yale admitted that the materials found in his bedroom were for the manufacture of methamphetamine. The Commonwealth alleged that Yale and Thompson were liable under both principal and accomplice theories of liability. Yale proceeded to a jury trial, and attempted to prove Thompson was solely responsible for the contraband found in Yale's bedroom. In support of this defense, Yale sought to introduce evidence of Thompson’s previous arrests for methamphetamine-related offenses. The Pennsylvania Supreme Court granted discretionary review to clarify the appropriate standard for the admission of evidence of a third person’s crimes, wrongs or other acts (“third person guilt”) offered by a criminal defendant in an effort to raise a reasonable doubt that he was not the perpetrator of the crime charged. The Superior Court applied the standard of admissibility typically associated with the Commonwealth’s introduction of crimes, wrongs or other acts evidence against a criminal defendant pursuant to Pennsylvania Rule of Evidence (“Pa.R.E.”) 404(b). The Supreme Court held that evidence of a third person’s guilt offered by a defendant is admissible if it is relevant pursuant to Pa.R.E. 4012 and not otherwise excludable pursuant to Pa.R.E. 403. Thus, the Supreme Court vacated the Superior Court order and remanded for further proceedings. View "Pennsylvania v. Yale" on Justia Law

In this case, jurors could not reach a unanimous verdict on some counts, and the trial court sua sponte declared a mistrial. Defendant Joshua Wardlaw objected to the mistrial, and sought a judgment of acquittal on the unresolved charges. The trial court denied Wardlaw’s motion. Wardlaw filed an interlocutory appeal to the Superior Court, claiming a right to do so pursuant to Pennsylvania Rule of Appellate Procedure 311(a)(6). The Superior Court quashed the appeal, holding that Rule 311(a)(6) did not apply because the trial court’s declaration of a mistrial was not an “award” of a new trial. The Pennsylvania Supreme Court granted Wardlaw’s request for discretionary review to consider whether the Superior Court’s interpretation of Rule 311(a)(6) was erroneous. The Pennsylvania Supreme Court found that Wardlaw did not appeal an order awarding a new trial, and the Superior Court correctly determined that Wardlaw was not entitled to an interlocutory appeal under Pennsylvania Rule of Appellate Procedure 311(a)(6). "One cannot award that which is not sought. Consequently, a new trial is awarded only when the court grants a party’s motion for a new trial. When the new trial flows from the declaration of a mistrial, the court has not awarded a new trial." The Superior Court’s order quashing the appeal was affirmed. View "Pennsylvania v. Wardlaw" on Justia Law

In January 2010, Appellant James Finnecy was sentenced to a maximum term of two years’ imprisonment for unauthorized use of a motor vehicle and theft by unlawful taking, as well as two consecutive terms of eighteen months’ probation for escape, resisting arrest, identity theft, and ten counts of forgery. In October 2011, Appellant was released from custody and placed on probation. He committed multiple probation violations over the next several months and also failed to complete a court supervised drug treatment program. The trial court ultimately revoked Appellant’s probation. In 2014, Appellant was sentenced to twelve to twenty-four months’ imprisonment, to be followed by five years’ probation. Appellant was again released from custody and paroled to a court supervised substance abuse treatment facility. Shortly thereafter, Appellant absconded from parole and committed numerous additional violations of his supervision. As a result, the Commonwealth filed a petition to revoke Appellant’s probation and parole, which was granted. Appellant was sentenced to an aggregate term of twelve and one-half to twenty-five years’ imprisonment. Relevant here, the court found Appellant ineligible for a sentence under the Pennsylvania Recidivism Risk Reduction Act (“RRRI Act”). The issue Appellant's case presented for the Pennsylvania Supreme Court's review centered on whether a single past conviction for violent crime demonstrated “history of present or past violent behavior” for purposes of the RRRI Act, thereby disqualifying an offender from eligibility for a reduced sentence. Before addressing this question, the Court first had to determine whether a trial court’s failure to impose a sentence under the RRRI Act implicated sentencing illegality. The Supreme Court held the trial court’s failure to sentence an eligible offender pursuant to the RRRI Act implicated sentencing illegality. The Court also found that a single prior conviction for a non-enumerated crime demonstrating violent behavior did not qualify as a history of past violent behavior under the Section 4503 of the RRRI Act. Accordingly, the Superior Court judgment was reversed in part and affirmed in part, and the case remanded for further proceedings. View "Pennsylvania v. Finnecy" on Justia Law

Appellee Anthony Shaw was tried jointly with a co-perpetrator for the 2009 attempted murder of Alex Adebisi. At the pretrial stage, Appellee’s counsel filed a notice of alibi. At trial, only one of two identified alibi witnesses in the notice was called by the defense to testify. During her cross-examination of the testifying witness, the prosecutor referred to the notice of alibi to impeach the alibi's veracity. Defense objected, arguing the notice was not the witness' statement. After the Commonwealth concluded the cross-examination, Appellee’s counsel asked for a sidebar conference and moved for a mistrial. After Appellee was convicted and an unsuccessful direct appeal was concluded, he lodged a petition under the Post Conviction Relief Act, claiming he received ineffective assistance of trial counsel for failing to amend the alibi notice prior to trial to remove the reference to a non-testifying alibi witness. The PCRA court denied relief on the post-conviction petition, Appellee appealed, and the Superior Court reversed and remanded for a new trial. With respect to trial counsel’s performance, the Superior Court found the alibi notice counsel had submitted failed to reflect his own contemporaneous understanding of the circumstances. And although counsel expressed a belief that an alibi witness could not be cross-examined with an alibi notice, the court referenced its own prior decisions which it read for the proposition that “it is well-established that an alibi notice can be used for impeachment purposes.” The Pennsylvania Supreme Court reversed the Superior Court, agreeing with the Commonwealth that the matter should have been remanded to the post-conviction court for Appellee to be afforded the opportunity to create an evidentiary record to meet his burden of demonstrating the ineffectiveness, particularly in terms of the reasonable-basis criterion. "We also find that the Superior Court should have provided the post-conviction court with the opportunity to assess prejudice in the first instance. ... Although certainly it is possible that the jurors relied on the notice to discredit the defense... it is most appropriate for the PCRA court to pass, in the first instance, on whether there is a reasonable probability that the outcome of Appellee's trial would have been different had counsel correctly handled the alibi notice." View "Pennsylvania v. Shaw" on Justia Law

In the pendency of divorce proceedings, Appellee and her husband entered into agreement governing the shared custody of their five-year-old child. Appellee repeatedly and intentionally violated this custody agreement, eventually absconding with the child ultimately to Florida, where the child remained for forty-seven days separated from her father. Appellee claimed the father was abusive, her attempts to secure assistance from the local children and youth agency had been rebuffed, and she had no option but to remove the child from the father’s care. Appellee was apprehended and charged with interference with custody of children. At trial, the Commonwealth presented testimony from the father, a clinical psychologist, a social worker, and a detective to the effect that Appellee’s allegations were false and/or unfounded. Appellee said she had been advised by a nanny the child had disclosed an incident of offensive touching by the father, and that subsequently the child repeatedly made statements to Appellee personally which were indicative of abuse. Appellee also presented the nanny’s corroborative testimony, and her cousin attested the child had apprised her of inappropriate touching too. The Pennsylvania Legislature prescribed that a defendant was innocent of the crime of “interference with custody of children” when he or she believed that intrusive actions were necessary to spare the subject child from danger. Appellee was convicted as charged and sentenced; in post-conviction proceedings, the Superior Court reversed sentence and ordered a new trial. The Commonwealth contended that the belief element of the offense should have been construed to encompass only beliefs that were held reasonably. The Pennsylvania Supreme Court found Commonwealth’s arguments "are too tenuous to be credited." The Superior Court judgment was affirmed. View "Pennsylvania v. H.D." on Justia Law