Justia Pennsylvania Supreme Court Opinion Summaries

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

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

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

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

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

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

In September 2007, Donte Thomas was convicted of first-degree murder and sentenced to death for the killing of Tyreese Gaymon. Thomas was also convicted of carrying a firearm on public streets, recklessly endangering another person, and conspiracy, though no sentences were imposed for these convictions. The murder occurred in February 2006, while Gaymon was standing on a street corner. Multiple witnesses identified Thomas as the shooter. Thomas was arrested in April 2006 and admitted to knowing Kareem Glass, who was awaiting trial for the murder of Gaymon’s cousin. Thomas denied shooting Gaymon but admitted to smuggling a cell phone into prison for Glass.On direct appeal, the Supreme Court of Pennsylvania affirmed Thomas’ conviction and sentence. Thomas then filed a timely petition under the Post Conviction Relief Act (PCRA) in October 2013, which he amended multiple times. The PCRA court held several hearings over two and a half years and ultimately dismissed Thomas’ petition in May 2023. Thomas appealed this dismissal.The Supreme Court of Pennsylvania reviewed Thomas’ claims, which included allegations of ineffective assistance of counsel and prosecutorial misconduct. Thomas argued that his trial counsel failed to consult with him adequately, investigate potential alibi witnesses, and object to prejudicial statements. He also claimed that the prosecution induced false testimony and withheld exculpatory evidence. The court found that Thomas’ counsel had met with him multiple times and that the potential alibi witnesses were either not credible or unavailable. The court also determined that the alleged prosecutorial misconduct did not deprive Thomas of a fair trial.The Supreme Court of Pennsylvania affirmed the PCRA court’s dismissal of Thomas’ petition, concluding that Thomas failed to prove his claims of ineffective assistance of counsel and prosecutorial misconduct. The court found no abuse of discretion in the PCRA court’s rulings. View "Commonwealth v. Thomas" on Justia Law

James Berry was convicted of sexually abusing two young family members. The court found that Berry had no prior convictions or juvenile adjudications, resulting in a prior record score of zero. However, the sentencing court imposed a sentence significantly above the standard range, citing Berry’s arrest record as a factor. Berry appealed, arguing that considering his arrest record, which did not result in convictions, was improper.The Superior Court affirmed the sentencing court’s decision, stating that a sentencing court may consider prior arrests as long as it recognizes that these arrests did not result in convictions. The court believed that Berry’s arrest record was relevant to his amenability to rehabilitation and the protection of the public.The Supreme Court of Pennsylvania reviewed the case and held that a sentencing court may not consider a defendant’s prior arrests that did not result in convictions. The court emphasized that prior arrests are not probative of a defendant’s character or likelihood of recidivism and are not relevant under the Pennsylvania Sentencing Code. The court noted that allowing prior arrests to influence sentencing would undermine the intent of the sentencing guidelines and the defendant’s prior record score.The Supreme Court vacated Berry’s sentence and remanded the case for resentencing without considering his prior arrest record. The court did not address the constitutional question of due process, as the case was resolved based on existing legal precedents regarding the irrelevance of prior arrests in sentencing. View "Commonwealth v. Berry" on Justia Law

On December 30, 2018, Phillip Walters reported his girlfriend, Hayley Lorenzen, missing. Lorenzen had recently moved into Walters' apartment. Walters claimed that after staying up late the previous night, he found Lorenzen missing the next morning. He contacted her father and then the police. On January 9, 2019, Gabel Bell, who had a prior relationship with Walters, informed the police that Walters had killed Lorenzen. Bell detailed that Walters had strangled Lorenzen and disposed of her body in a river. Lorenzen's remains were found on July 20, 2019, leading to Walters being charged with first-degree murder, strangulation, and abuse of a corpse.The Wyoming County Court of Common Pleas convicted Walters, and he was sentenced to life imprisonment without parole. Walters appealed, arguing that the trial court erred in admitting the testimony of Dr. Gary Ross, the pathologist, who concluded that Lorenzen's cause of death was "strangulation by history" based solely on Bell's account, without physical evidence. The Superior Court affirmed the conviction, reasoning that the pathologist's reliance on case history was permissible.The Supreme Court of Pennsylvania reviewed the case and found that Dr. Ross' testimony did not meet the requisite standard of being offered to a reasonable degree of medical certainty. Dr. Ross admitted that his conclusion was based solely on Bell's statements and not on any objective medical findings due to the advanced decomposition of Lorenzen's body. The court held that this testimony improperly bolstered Bell's credibility, encroaching on the jury's role in determining witness credibility. Consequently, the court vacated Walters' judgment of sentence and remanded the case for a new trial. View "Commonwealth v. Walters" on Justia Law

Thomas E. Bold, Jr. was found unconscious behind the wheel of his legally parked car in a mall parking lot. The car's engine was running, and the headlights were on. When roused by Officer Thomas Gelnett, Bold appeared intoxicated and admitted to drinking at a nearby bar. He intended to sleep in his car until he was fit to drive. Bold was arrested for DUI and refused a blood test at a medical facility. Consequently, PennDOT suspended his license for 18 months due to his refusal.Bold appealed the suspension in the Cumberland County Court of Common Pleas. During the hearing, Officer Gelnett admitted there was no evidence that Bold had driven the car while intoxicated. The court initially upheld the suspension but later reversed its decision, finding no reasonable grounds to believe Bold was in control of the vehicle's movement. The court cited the case Solomon v. PennDOT, which found insufficient grounds for suspicion when a suspect was found sleeping in a parked car with the engine running.The Commonwealth Court reversed the trial court's decision, holding that the officer had reasonable grounds to believe Bold was in actual physical control of the vehicle. The court relied on past cases where the presence of a driver in a running vehicle was deemed sufficient for reasonable grounds. However, the Supreme Court of Pennsylvania found that the circumstances did not provide reasonable grounds to believe Bold was operating or in actual physical control of the vehicle's movement. The court emphasized that the implied consent law requires some objective evidence of control over the vehicle's movement. Consequently, the Supreme Court reversed the Commonwealth Court's ruling, siding with Bold. View "Bold v. Commonwealth" on Justia Law