Justia Pennsylvania Supreme Court Opinion Summaries

In May 2013, Appellant Todd Hoover pled guilty to one count of driving under the influence of alcohol (“DUI”) - general impairment, and one count of DUI - highest rate of impairment. On August 13, 2013, the trial court sentenced Appellant to a term of five years intermediate punishment, which included 90 days incarceration at the Lycoming County Prison pre-release facility. He was also ordered to pay the costs of prosecution and a fine. In 2017, Appellant filed a motion for early termination of his sentence of intermediate punishment. On September 29, 2017, the trial court determined that Appellant had “complied with all conditions of supervision, paid all fines and costs, and completed all obligations” associated with his county intermediate punishment, and, accordingly, granted his petition. That night, however, Appellant was arrested for, and charged with, another DUI offense. The Lycoming County Adult Probation Office (“LCAPO”) contacted the trial court and orally requested that it reconsider its order granting Appellant’s petition for early termination of his sentence. The trial court granted the request the same day, and scheduled a hearing to consider “whether the Court should vacate its Order releasing [Appellant] from supervision in light of the new charges.” In the interim, the Commonwealth filed a petition to revoke Appellant’s probation, asserting that his new DUI offense constituted a violation of his probation. The Pennsylvania Supreme Court's review centered on whether the trial court erred by vacating, pursuant to 42 Pa.C.S. section 5505, its prior order granting a petition for early termination of a sentence of intermediate punishment based on the court’s discovery that the defendant committed a new offense shortly after the early termination order was entered. To this, the Supreme Court concluded the trial court erred, and, therefore, reversed the decision of the Superior Court affirming the trial court’s order. View "Pennsylvania v. Hoover" on Justia Law

In 2002, Walter Smith told police that Clinton Robinson killed Margaret Thomas. Later that year, Smith himself was killed when he was shot twelve times outside a Philadelphia bar. Based on ballistics evidence, the police concluded that multiple individuals had acted in concert to kill Smith. Police recovered a red baseball cap approximately nine feet from Smith’s body. The case remained unsolved until 2005, when a jailhouse informant told police he had overheard Appellant Kareem Johnson make statements implicating himself in Smith’s murder. The informant admittedly supplied this information solely in hopes of obtaining leniency when he was sentenced in federal court. DNA testing revealed that Appellant was a contributor to the DNA in the sweatband of the red cap. The Commonwealth proceeded on the understanding that there was only one baseball cap involved, and that it contained both Smith’s blood and Appellant’s DNA. A jury would convict Appellant on all counts, and sentenced him to death. Appellant moved for post-conviction relief, and was eventually granted a new trial. Appellant called as witnesses several individuals who were involved with the Commonwealth’s case at the 2007 trial or who had represented the Commonwealth in post-conviction proceedings. In questioning these witnesses, Appellant was able to uncover in some detail the extent of the Commonwealth’s mishandling of physical and DNA evidence during his trial; from this he moved to bar retrial. Appellant argued that, whether errors reflected an intentional subversion of the truth-determining process, or mere recklessness, they led to Appellant being confined on death row based on a trial the Commonwealth later conceded was constitutionally inadequate. The Pennsylvania Supreme Court found that although Commonwealth's acts and omissions were not made intentionally or with specific purpose to deprive Appellant of his rights, the record was consistent with the trial court's characterization that such mistakes were "unimaginable." As such, the Supreme Court found the Pennsylvania Constitution immunized Appellant from being put in jeopardy a second time. View "Pennsylvania v. Johnson" on Justia Law

Appellant Keenan Coleman petitioned for post conviction relief; he was convicted by jury of first-degree murder for the 2010 shooting death of Tobias Berry. Appellant argued he received ineffective assistance of trial counsel, arguing the trial court failed to properly instruct the jury on the use of certain hearsay testimony, trial counsel failed to object to other testimony, and trial counsel failed to object to a portion of the prosecutor's closing argument. After review of the trial court record, the Pennsylvania Supreme Court affirmed in part and reversed in part. The Supreme Court determined the trial court indeed erred by not instructing the jury to consider the alleged hearsay testimony for limited purposes, and the PRCA court did not adequately address the issue raised from testimony regarding Appellant's alleged ownership and use of firearms. The Supreme Court affirmed the PCRA court's rejection of Appellant's ineffective assistance claim with respect to the prosecutor's closing argument. The matter was therefore remanded for further proceedings. View "Pennsylvania v. Coleman" on Justia Law

In 2015, appellant John Koehler filed his second petition for collateral relief pursuant to the Post Conviction Relief Act (“PCRA”). In 1996, a jury found Koehler guilty of two counts of first-degree murder and related offenses arising from the killing of his girlfriend and her nine-year-old son, and sentenced Koehler to death. In 2001, Koehler filed a timely PCRA petition. Therein, Koehler included a claim for relief from his death sentence due to ineffectiveness of counsel during the penalty phase. The PCRA court denied relief following a hearing, and Koehler appealed. The Pennsylvania Supreme Court affirmed. Then in 2015, Koehler filed a second PCRA petition, this time asserting that his due process rights had been violated during his 2012 appeal. Koehler premised this assertion upon the involvement of a former Pennsylvania Supreme Court justice in a well-publicized email scandal that included the exchange of religiously, racially, and sexually offensive emails. Viewing the subject of the infamous emails as suggesting a disregard for victims of domestic violence, Koehler alleged that the justice's participation in his previous appeal raised a risk of actual judicial bias, as well as the appearance of bias. Recognizing that his second PCRA petition was facially untimely, Koehler asserted that he met the timeliness exceptions for governmental interference and newly discovered facts. Koehler sought, inter alia, the reinstatement of his appellate rights nunc pro tunc in order to appeal anew to the Pennsylvania Supreme Court the denial of his first PCRA petition. The PCRA court dismissed the petition, holding that it was without authority to grant relief. The Supreme Court concluded that the PCRA court erred as a matter of law, as it did possess the authority to grant the form of relief that Koehler sought in the event that he established the merits of his claim. Accordingly, the PCRA court's order was reversed, and the matter remanded for further proceedings. View "Pennsylvania v. Koehler" on Justia Law

Appellant Donald Tedford was convicted of first-degree murder and rape on February 6, 1987. He appealed the dismissal of his second petition for relief filed pursuant to the Post Conviction Relief Act (“PCRA”), on December 2, 2014, as amended by a counseled petition on May 5, 2015, and a supplemental petition filed on June 9, 2015. In connection with his initial filings, Tedford sought wholesale discovery of the prosecution’s entire file, but the PCRA court concluded that the petition (as amended) was not timely filed. Tedford also appealed the PCRA court’s order denying his supplemental PCRA petition, in which he requested discovery, an evidentiary hearing, and/or a new trial based upon the admission of expert testimony presented at trial related to microscopic hair analysis. The PCRA court concluded that pursuant to PCRA Section 9545(b)(1)(ii), it had jurisdiction to consider the merits of Tedford's newly-discovered-facts claims, but ultimately it concluded Tedford had not asserted a meritorious claim in accordance with Section 9543(a)(2)(vi). Finding no reversible error in that analysis, the Pennsylvania Supreme Court affirmed dismissal of the petition for relief. View "Pennsylvania v. Tedford" on Justia Law

The trial court granted Timothy Trahey’s motion to suppress the results of a blood test that revealed his blood alcohol concentration (“BAC”), finding no justification for the investigating officers’ failure to obtain a search warrant before conducting the test. On the Commonwealth’s appeal, the Superior Court reversed, opining that the Commonwealth’s evidence sufficiently established the existence of exigent circumstances, thus excusing the absence of a warrant. The Pennsylvania Supreme Court reversed, finding that while the exigency analysis is an objective one, "even disregarding the officers’ subjective motivations, or their candid acknowledgment that they would have obtained a search warrant if they thought it necessary, there was no time-sensitive need to conduct a warrantless blood test under the circumstances of this case. Accordingly, the Superior Court’s conclusion that the test was justified by exigent circumstances was drawn in error." View "Pennsylvania v. Trahey" on Justia Law

In August 2015, a deputy sheriff conducted a vehicle stop of Appellant Victor Copenhaver’s pickup truck. Upon approaching the truck, the deputy noticed an odor of alcohol and marijuana emanating from the passenger compartment. After administering field sobriety tests, he arrested Appellant for suspected driving under the influence of alcohol and controlled substances (“DUI”). Appellant was ultimately charged with DUI and other offenses. Appellant challenged the deputy’s authority to conduct a traffic stop and sought suppression of all evidence obtained during the encounter. Rather than presenting testimony at a suppression hearing, the parties stipulated that Appellant was driving the vehicle in question and that the deputy had training and qualifications equivalent to that of a police officer. The parties also agreed that the vehicle stop occurred as a result of the deputy observing the tailgate to the pickup truck being in a down position, which caught the deputy's attention. The deputy further observed the registration on the pickup truck was expired, and additionally, the registration number was identified as belonging to a vehicle other than the one on which it was attached. The issue this case presented for the Pennsylvania Supreme Court's review was whether the deputy could lawfully conduct the traffic stop based on the expired registration sticker, on a theory that such a violation amounts to a breach of the peace. The Supreme Court concluded driving a vehicle with an expired registration did not entail a breach of the peace. It vacated the superior court's order insofar as it held that the expired registration was a breach of the peace, thus alone authorizing the deputy to stop Appellant's vehicle. Notably, in light of its holding, the Supreme Court found the superior court did not proceed to consider other relevant questions, such as whether the parties’ factual stipulation should have been read as indicating that the officer’s understanding that the registration sticker was associated with a different vehicle arose in the pre-stop timeframe – consistent with the Commonwealth’s position throughout this litigation. "These issues should be resolved in the first instance by the intermediate court on remand." View "Pennsylvania v. Copenhaver" on Justia Law

California law enforcement officers interviewed Appellant Stacy Britton in her California residence and, unbeknownst to her, recorded those interviews. Over Appellant’s objection, Pennsylvania used those recordings as evidence to help convict Appellant of murder in Pennsylvania. The Pennsylvania Supreme Court granted allowance of appeal to examine whether the California law enforcement officers were acting as agents of the Pennsylvania State Police when they recorded the interviews with Appellant in her California home, and if so, whether Pennsylvania's constitutional and statutory protections were available to Appellant under those circumstances. The Court concluded the California law enforcement officers were not acting as agents of the Pennsylvania State Police when they interviewed Appellant, making analysis of whether any Pennsylvania-specific constitutional or statutory protections unwarranted. Because the Supreme Court concluded the Pennsylvania trial court reached the proper result in this matter, it affirmed that court's judgment. View "Pennsylvania v. Britton" on Justia Law

On September 20, 2010, at age of 13 appellant, H.R., was adjudicated delinquent for indecent assault of a complainant less than 13 years of age. Appellant was placed on official probation and, pursuant to Section 6352 of the Juvenile Act, was ordered to undergo inpatient treatment at a sex offender residential treatment facility. Appellant remained in treatment when he turned 20 in February 2017 and he was assessed pursuant to Section 6352, the results of which found that involuntary treatment at a sex offender residential treatment facility pursuant to the Court-Ordered Involuntary Treatment of Certain Sexually Violent Persons Statute (Act 21) was still necessary. On January 4, 2018, following a hearing, a trial court denied appellant's motion to dismiss and granted the petition for involuntary treatment, determining appellant was an sexually violent delinquent child (SVDC) and committing him to one year of mental health treatment. On appeal, appeal, appellant argued: (1) Act 21 was punitive in nature, and this its procedure for determining whether an individual was an SVDC was unconstitutional; and (2) retroactive application of amendments to Act 21 made effective in 2011, was also unconstitutional. The Pennsylvania Supreme Court determined the superior court correctly determined the relevant provisions of Act 21 were not punitive, were constitutional, thus, affirming the trial court's order. View "In re: H.R." on Justia Law

Appellee William Housman petitioned for post-conviction relief, and appealed when that relief was denied. Housman was accused of murdering Leslie White in 2000. He was convicted by jury of first-degree murder, kidnapping, theft by unlawful taking or disposition, unlawful restraint, abuse of a corpse, and criminal conspiracy. The Commonwealth sought the death penalty for Housman and his co-defendant, his former girlfriend, Beth Ann Markman. The Commonwealth appealed the PCRA court’s grant of a new penalty-phase trial, and Housman cross-appealed the court’s denial of guilt-phase relief. The Pennsylvania Supreme Court concluded the record supported the PCRA court’s determination that Housman’s claim that trial counsel was ineffective for failing to investigate and present mitigating evidence at his penalty phase had arguable merit; that trial counsel’s performance lacked a reasonable basis; and that Housman suffered prejudice as a result of counsel’s ineffectiveness. Accordingly, with respect to the Commonwealth’s appeal, the Supreme Court affirmed the PCRA court’s grant of a new penalty trial. In light of the Court's affirmance of the PCRA court’s grant of a new penalty trial, the Court did not address Housman’s remaining penalty-phase claims. View "Pennsylvania v. Housman" on Justia Law