Justia Pennsylvania Supreme Court Opinion Summaries

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

Appellant William Rohland was an inmate confined at SCI-Huntingdon. In 2005, he was charged in Lackawanna County, Pennsylvania, with various offenses. He was ultimately sentenced on those charges in November 2006 to one-to-five years’ imprisonment, and was required as part of his sentence to pay restitution, fines, and costs. Thereafter, in 2007, Appellant was convicted in Luzerne County on two counts of first-degree murder and sentenced to two consecutive terms of life imprisonment. As of December 2016, the Department of Corrections' records reflected Appellant still owed approximately $2,300 in connection with his Lackawanna County sentence, although the incarceration aspect of that sentenced had expired. Thus, the prison’s business office sent Appellant a memorandum notifying him of the amount owed and indicating that the prison would begin making periodic Act 84 deductions from his inmate account to satisfy that obligation. The memo also gave instructions on how Appellant could challenge the deductions. The issue this case presented for the Pennsylvania Supreme Court's review was whether the deductions from an inmate account could continue after Appellant finished serving the prison-term portion of the sentence while still incarcerated on a separate sentence. The Supreme Court determined the Department had clear legal authorization under Act 84 to effectuate such deductions. That being the case, the Supreme Court determined the Commonwealth Court acted properly in granting the Department's motion for summary judgment. View "Rohland v Business Office, Dept. of Corrections" on Justia Law

The Commonwealth of Pennsylvania challenged a superior court's application of United States v. Cronic, 466 U.s. 648 (1984) to find that trial counsel's failure to secure a Spanish language interpreter for appellee Miguel Diaz on the first day of his trial for charges relating to rape, rape of a child, endangering the welfare of children, statutory sexual assault, indecent assault, corruption of minors, and conspiracy. The argument was that failure in not securing a translator was prejudice per se because Diaz was not a native English speaker, and could not fully understand the proceedings. After review, the Pennsylvania Supreme Court concluded that where the absence of a needed interpreter at a critical stage of trial obstructs his ability to communicate with counsel, Cronic applies such that the defendant need not prove he or she was prejudiced by a Sixth Amendment violation. Based on the record, the Supreme Court found the Superior Court correctly concluded that Cronic was applicable and that no specific showing of prejudice was required because of the absence of an interpreter on the first day of trial during critical stages of the proceeding. View "Pennsylvania v. Diaz" on Justia Law

The Pennsylvania Supreme Court granted discretionary review to determine whether the procedure used to designate certain individuals convicted of sexual offenses as sexually violent predators (SVPs), codified at 42 Pa.C.S. section 9799.24(e)(3), was constitutionally permissible in light of the Court's decision in Commonwealth v. Muniz, 164 A.3d 1189 (Pa. 2017). The Superior Court extrapolated from our decision in Muniz to hold the lifetime registration, notification, and counseling requirements (RNC requirements) applicable to SVPs pursuant to 42 Pa.C.S. sections 9799.15, 9799.16, 9799.26, 9799.27, and 9799.36 were increased criminal punishment such that the procedure for conducting SVP determinations violated the requirements of Apprendi v. New Jersey, 530 U.S. 466 (2000) and Alleyne v. United States, 570 U.S. 99 (2013). The Pennsylvania Supreme Court held RNC requirements did not constitute criminal punishment and therefore the procedure for designating individuals as SVPs under 9799.24(e)(3) was not subject the requirements of Apprendi and Alleyne, and remained constitutional. View "Pennsylvania v. Butler" on Justia Law

Thirty years ago, Appellee Otto Young was sentenced to twenty-five years in prison after he was convicted of aggravated assault, burglary, terroristic threats, and conspiracy. He was repeatedly released on parole and his parole was repeatedly revoked. On three occasions, the revocations were due to crimes that Young committed while at liberty on parole. This case presented a straightforward issue for the Pennsylvania Supreme Court’s review, namely whether the Board of Probation and Parole (the “Board”) had the statutory authority to rescind a previous grant of credit for time spent at liberty on parole. The Supreme Court agreed with the Commonwealth Court’s determination that the Board lacked any such statutory authority and thus affirmed its order. View "Young v. PA Board of Probation & Parole" on Justia Law

On the night of May 29, 2012, appellant Patrick Tighe, then 58 years old, sexually assaulted a minor female victim, J.E., then 15 years old. In this discretionary appeal, the Pennsylvania Supreme Court examined whether the trial court improperly limited appellant’s right to self-representation in violation of the Sixth Amendment to the United States Constitution and Article I, Section 9 of the Pennsylvania Constitution when, during appellant’s jury trial, the court prohibited appellant, who was proceeding pro se, from personally conducting cross-examination of the victim-witness, and instead required stand-by counsel to cross-examine the witness using questions prepared by appellant. The Supreme Court concluded there was no constitutional violation and affirmed the order of the Superior Court. View "Pennsylvania v. Tighe" on Justia Law

Appellant Harold Cost was arrested for various firearms offenses and filed a motion to suppress. At a hearing, the lead investigating officer initially explained that he was patrolling a high crime area in Philadelphia in an unmarked vehicle at approximately 9 p.m., when his partner observed Appellant and three other individuals in an alley. The officer suspected "there might be something going on," circled the block and stoped his vehicle in front of the alleyway to investigate. The officer did not activate the vehicle's emergency sirens or lights, however, he announced "police" when exiting the vehicle. The issue this case presented was whether the officer's retention of an individual's identification card was a seizure in terms of the Fourth Amendment. Specifically, the issue reduced to whether a reasonable person would feel free to ignore the police presence and proceed about his business while, amongst the other circumstances presented, the person is questioned by police as an officer continues to hold his identification and conducts a warrant check. The Pennsylvania Supreme Court concurred with the suppression court that appellant was indeed seized. View "Pennsylvania v. Cost" on Justia Law