Justia Pennsylvania Supreme Court Opinion Summaries

The issue presented for the Pennsylvania Supreme Court's review centered on whether the Wiretapping and Electronic Surveillance Act made inadmissible a a covertly obtained audio recording of Appellee Beth Ann Mason while she worked as a nanny in the home of the family that employed her. Because Appellee failed to demonstrate that she possessed a justifiable expectation that her oral communications would not be subject to interception by a recording device located in the children’s bedrooms, the Pennsylvania Supreme Court held that the Wiretap Act did not preclude the Commonwealth from introducing these recordings as evidence at Appellee’s trial for allegedly abusing the children in her care. The Supreme Court reversed the Superior Court’s judgment, which held that the trial court properly suppressed the subject audio recording. The matter was remanded for further proceedings. View "Pennsylvania v. Mason" on Justia Law

This appeal concerned the application of the statutory compulsory joinder rules, which generally require a prosecutor to pursue, in a single proceeding, all known charges against a defendant arising from a single criminal episode occurring within the same judicial district, subject to enumerated exceptions. In 2015, as the result of a traffic stop, Appellant Dewitt Johnson was arrested and charged with driving with a suspended license, possession with intent to deliver heroin (“PWID”), and knowing and intentional possession of heroin (“K&I”). Before the Traffic Division of the Municipal Court of Philadelphia, he was found guilty, in absentia, of the summary traffic offense. The Municipal Court’s jurisdiction was capped at criminal offenses punishable by imprisonment for a term of not more than five years; because of this, the Commonwealth pursued the drug offenses in the common pleas court. Appellant moved to dismiss, contending the prosecution was required to try all of the offenses simultaneously, per the compulsory joinder requirements of Section 110 of the Pennsylvania Crimes Code. The Commonwealth conceded it was foreclosed from pursuing the K&I charge, because that crime, like the traffic offense, fell within the Municipal Court’s jurisdiction. Nevertheless, the Commonwealth argued that PWID remained viable, since the Municipal Court had lacked jurisdiction over that offense. In this regard, the Commonwealth invoked Section 112(1) of the Crimes Code, which served as an exception to Section 110’s general prohibition. The Superior Court accepted this argument and affirmed with respect to PWID. The Pennsylvania Supreme Court reversed the Superior Court and remanded the matter for dismissal of the PWID charge: "the Commonwealth must generally assure that known offenses are consolidated at the common pleas level, when they arise out of a single criminal episode and occur in the same judicial district." View "Pennsylvania v. Johnson" on Justia Law

In a probation revocation case, the trial court entered an order removing the District Attorney’s Office and appointing a private criminal-defense attorney to represent the Commonwealth as a “special prosecutor.” Because the Pennsylvania Supreme Court concluded the court lacked the authority to make such an appointment, the trial court’s order was vacated and the matter remanded for further proceedings. View "Pennsylvania v. Mayfield" on Justia Law

The Pennsylvania Supreme Court granted review in this case to determine the propriety of raising a claim in a habeas corpus petition that the sentencing statute under which Appellant was sentenced was unconstitutionally vague, or if such a claim was properly considered an illegal sentence claim cognizable solely under the mandates of the Post-Conviction Relief Act (PCRA). Appellant Ingram Moore was convicted by jury of first degree murder and possession of an instrument of crime for the 1993 murder of Kevin Levy. He was sentenced to life without the possibility of parole. He filed a federal writ of habeas corpus, which was dismissed as time barred. In April 2015, Appellant filed a Petition for Writ of Habeas Corpus ad Subjiciendum. Appellant’s petition lay dormant until he filed a Motion to Compel Disposition on March 12, 2016. Appellant then filed another Petition for Writ of Habeas Corpus on April 15, 2016 raising a claim that his continued incarceration was illegal as the statute he was sentenced under was unconstitutionally vague for failing to give defendant notice that a sentence of life imprisonment meant without parole. A trial court ultimately dismissed Appellant’s petitions on May 31, 2017 “pursuant to the [PCRA].” Appellant appealed pro se. The Superior Court affirmed the trial court’s dismissal and held the trial court correctly viewed Appellant’s petitions for habeas relief as petitions for post-conviction relief under the PCRA. In making this determination, the Superior Court noted a writ of habeas corpus was properly considered a PCRA petition if the issue raised was cognizable under the PCRA. Appellant conceded that an issue cognizable under the PCRA must be brought through the PCRA’s procedures. Appellant asserted his claim that the statute he was sentenced under was void for vagueness was not a claim that fell within the specified claims available for relief under the PCRA and therefore was properly brought in a habeas petition. The Supreme Court disagreed, finding his arguments fell within the PCRA's purview. The trial court correctly dismissed his petition; the Superior Court's order was affirmed. View "Pennsylvania v. Moore" on Justia Law

The Pennsylvania Supreme Court granted certiorari review in this matter to determine whether the Department of Transportation (PennDOT) was precluded from suspending an individual’s driving privileges based on a DUI conviction, where there was a lengthy delay between the conviction and the time the driver was notified of the suspension. Under the facts of this case, the Court concluded the trial court’s finding – that Appellee would suffer prejudice if the suspension were to be imposed at this juncture – was supported by competent evidence of record, and moreover, it demonstrated that prejudice would follow from the fact of the delay itself. Additionally, there was no dispute that Appellee did not accrue any additional Vehicle Code violations after his predicate DUI conviction. The Court therefore agreed with the Commonwealth Court majority that a suspension at this late date will have lost much of its effectiveness with regard to its underlying legislative purposes, result in prejudice which can be attributed to the delay, and ultimately deny fundamental fairness. View "PennDOT Bureau of Driver Lic. v. Middaugh" on Justia Law

The issue presented for the Pennsylvania Supreme Court's review centered on whether a line of superior court cases changed the procedural requirements of Section 1106 of the Pennsylvania Judicial Code requiring restitution be set at the time of sentencing. Appellant Steven Cochran, II, briefly stayed at a vacation home owned by his grandparents. In late 2016, Appellant’s grandparents visited the home and found Appellant intoxicated. An altercation ensued, during which Appellant threatened and assaulted his grandmother, and deliberately destroyed various items of personal property. Also during the altercation, a fire was ignited, causing additional damage to the premises and personal property. Appellant was arrested and charged with terroristic threats, simple assault, two counts of criminal mischief, and three counts of harassment. At the beginning of the plea hearing, both counsel informed the trial court that the total restitution claimed exceeded $65,000.00, but that Appellant disputed whether he was responsible for that total amount because some of the destroyed or damaged property had belonged to him. Appellant entered a plea of guilty to one count each of terroristic threats, simple assault, and criminal mischief. In the non-restitution proceedings on June 29, 2017, the trial court sentenced Appellant to an aggregate terms of three to 23 months' incarceration, minus time served. A restitution hearing was set for August 28, 2017. Appealing the eventual amount of restitution ordered, Appellant objected to the trial court's jurisdiction, arguing more than 30 days had passed since the June 2017 order, and that the Commonwealth failed “to make a recommendation for restitution and the trial court failed to set restitution at the time of sentencing on June 29, 2017, as required by 18 Pa.C.S. 1106(c)(2).” A panel of the superior court agreed the trial court erred in failing to set restitution at the time of sentencing, reversed, and remanded fur resentencing. The Supreme Court determined that the superior court erroneously presumed that the “time of sentencing” for the purpose of section 1106 occurred solely on June 29, 2017. Because the final complete sentencing order was entered on September 15, 2017, the Supreme Court concluded Appellant had no basis to challenge the sentencing court’s jurisdiction under Section 1106 (c)(2). View "Pennsylvania v. Cochran II" on Justia Law

A court of common pleas granted Appellant Noel Montalvo's petition for post-conviction relief by granting a new guilt-phase trial. The Commonwealth appealed the PCRA court’s grant of a new guilt-phase trial; it did not challenge the PCRA court’s grant of a new penalty-phase trial. Appellant cross-appealed to challenge the trial court's rejection of "a myriad of additional bases for granting him a new guilt-phase trial." Appellant was accused of killing, or acting as an accomplice to the killing of his brother's estranged common law wife and the man she may have briefly dated. Appellant's brother was convicted on two counts of first-degree murder and one count of burglary, for which he was sentenced to death. Appellant would be convicted by jury on first-degree murder charges for the death of his brother's wife, the second-degree murder of her companion, conspiracy to commit murder and burglary. The jury determined the aggravating circumstances outweighed the mitigating circumstances in Appellant's case, and recommended a sentence of death. The PCRA court granted appellant's petition for relief on grounds of ineffective assistance of trial counsel. After review, the Pennsylvania Supreme Court agreed with the PCRA court that appellant established his ineffectiveness claim, and therefore, a new guilt-phase trial was warranted. In light of this conclusion, the Court did not address the issues raised by appellant in his cross-appeal. View "Pennsylvania v. Montalvo" on Justia Law

The Pennsylvania Supreme Court granted Appellant Keith Alexander's petition for allowance of appeal asking the Court to overrule or limit Commonwealth v. Gary, 91 A.3d 102 (Pa. 2014) (OAJC), a plurality result announcing that, without limitation, the federal automobile exception to the warrant requirement of the Fourth Amendment to the federal Constitution applied in Pennsylvania. "What Gary did not settle is whether the federal automobile exception is consistent with Article I, Section 8 of the Pennsylvania Constitution." The Court held Article I, Section 8 afforded greater protection than the Fourth Amendment, and reaffirmed prior decisions: the Pennsylvania Constitution required both a showing of probable cause and exigent circumstances to justify a warrantless search of an automobile. View "Pennsylvania v. Alexander" on Justia Law

Mitchell Gregory Peck, Jr. (“Peck”) was convicted of drug delivery resulting in death, and sentenced to twenty to forty years of imprisonment. In this appeal, the Pennsylvania Supreme Court considered the interplay between the territorial application of the Crimes Code, including in particular Section 102, 18 Pa.C.S. section 102, and the sufficiency of the evidence to support a conviction. Specific to this appeal, the Court addressed whether Peck’s conviction was supported by sufficient evidence where the drug delivery occurred in Maryland and the resulting death occurred in Pennsylvania. While the Commonwealth had subject matter jurisdiction to prosecute Peck for DDRD, the Supreme Court determined it could not present evidence to support his conviction. The Superior Court’s decision to the contrary was reversed and Peck’s judgment of sentence was vacated. View "Pennsylvania v. Peck Jr." on Justia Law

Melvin Knight appealed the death sentence he received for his role in the 2010 torture and murder of Jennifer Daugherty (“the Victim”), a 30–year-old intellectually disabled woman. On direct appeal, Appellant raised fourteen issues for the Pennsylvania Supreme Court’s review, including a challenge to the jury’s failure to find as a mitigating circumstance Appellant’s lack of a significant history of prior criminal convictions. In addressing this claim, the Court observed that it was undisputed that Appellant had no prior felony or misdemeanor convictions, a fact to which the prosecutor conceded during closing argument. The Supreme Court largely rejected Appellant's contentions of error, finding that Appellant’s sentence of death was not the product of passion, prejudice, or any other arbitrary factor, but, rather, was fully supported by the evidence that Appellant and his co-defendants held the intellectually-disabled victim against her will for several days, during which time they continuously subjected her to myriad forms of physical and emotional torture, eventually stabbing her in the chest, slicing her throat, strangling her, and stuffing her body into a trash can which they left outside under a truck. As the jury found that the aggravating circumstances outweighed the mitigating circumstances, the Court found Appellant’s sentence complied with the statutory mandate for the imposition of a sentence of death. View "Pennsylvania v. Knight" on Justia Law