Justia Pennsylvania Supreme Court Opinion Summaries

Appellant Leon Mills challenged a superior court decision to overturn a county court’s finding of a violation of Rule of Criminal Procedure 600 that he receive a prompt trial. The Rule requires that trial commence within 365 days from the date the criminal complaint is filed. Delays at any stage of the proceedings caused by the Commonwealth when it fails to exercise due diligence count in the 365-day tally. On June 6, 2011, the Commonwealth filed a complaint against Appellant charging him with a series of crimes arising out of a drive -by shooting, including attempted murder and aggravated assault. At a status meeting on March 20, 2012, however, per the Commonwealth's request, trial was continued. Trial was rescheduled to September 10, 2012. The outcome of the dismissal motion turned on whether or not 174 days was to be included or excluded in the 365 -day calculation. The common pleas court enforced the rule's main directive, and dismissed. Upon review, the Pennsylvania Supreme Court agreed with Appellant that time attributable to the normal progression of a case simply was not "delay" for purposes of Rule 600, and reinstated the dismissal order. View "Pennsylvania v. Mills" on Justia Law

Appellee was charged with a single count of possession with intent to distribute, or possession, of a “designer drug,” a substance similar to a scheduled controlled substance, not the same. The trial court here determined experts have been unable to reach an agreement on a method for analyzing and determining the similarities between the chemical structures the controlled substance and its designer analogue, leading it to conclude this disagreement rendered the Pennsylvania designer drug statute unconstitutionally vague. The Pennsylvania Supreme Court reversed, finding the common pleas court did not account for the difference between the concepts of analogue and substantial similarity, the latter of which is more readily apprehensible to the lay citizen in the context of comparing chemical structures; nor did it recognize that, unlike the controlled-substance provision, the designer drug provision included a narrowing scienter specification. Moreover, the Court found in this case that there were “considerable similarities” as between the two molecules based on their two-dimensional diagrams. View "Pennsylvania v. Herman" on Justia Law

The Pennsylvania Supreme Court affirmed appellant Marcel Johnson’s convictions and his sentence of death for the 2013 murder of Ebony Talley, her unborn child, and her four-year-old daughter, R.R. In this automatic direct appeal, Johnson raised nine issues for review. After thorough consideration of these issues, the Court affirmed his convictions and the imposition of the death sentence. View "Pennsylvania v. Johnson" on Justia Law

Trial courts must identify the circumstances that make it reasonable to infer that the property owner had actual knowledge of the illegal use of the property or consented to the underlying criminal activity before allowing a civil in rem forfeiture of that property. The proper constitutional construct in determining whether an in rem forfeiture violates the Excessive Fines Clause of the Eighth Amendment requires an initial determination regarding the relationship between the forfeited property and the underlying offense (the instrumentality prong). If this threshold prong is satisfied, the next step of the analysis is a proportionality inquiry in which the value of the property sought to be forfeited is compared to the gravity of the underlying offense to determine whether the forfeiture is grossly disproportional to the gravity of the offense. A 71-year-old grandmother who owned the house in which she lived, and owned a 1997 Chevrolet minivan, suffered from blood clots in her lungs, was hospitalized, and released, ordered to bed rest. Her adult son and two grandchildren also lived in the house. The son sold drugs from the house and the van, without his mother’s knowledge. The Commonwealth filed a petition for forfeiture of the house and minivan, with the trial court determining there was a nexus between the seized house and violations of the Controlled Substance, Drug, Device and Cosmetic Act (Drug Act). The trial court rejected the grandmother’s statutory innocent owner defense afforded by the Forfeiture Act because, after the police notified her of her son’s drug activities (through service of search warrants and personally informing her of the activities) she “refused to take any proactive measures or steps to demonstrate her lack of consent to this illegal activity. The Commonwealth Court reversed the trial court, concluding that the lower tribunal applied an erroneous standard for determining whether the forfeiture violated the Eighth Amendment, and that it failed to consider all relevant circumstances in rejecting the innocent owner defense. The Pennsylvania Supreme Court agreed and affirmed the Commonwealth Court. View "Pennsylvania v. 1997 Chevrolet, etc." on Justia Law

The issue presented for the Supreme Court’s review in this case centered on whether the Pennsylvania Board of Probation and Parole (the “Board”) abused its discretion if it fails to consider whether to grant a convicted parole violator (“CPV”) credit for time spent at liberty on parole. Also for consideration was whether the Board had to provide a contemporaneous statement explaining the rationale behind its decision to grant or deny credit to a CPV. In 2010, following his guilty plea to possession with intent to deliver (“PWID”), Appellant was sentenced to two to four years of imprisonment, with a maximum sentence date of December 9, 2013. On December 12, 2011, the Board released Appellant on parole. In 2013, while still on parole, Appellant was arrested and charged with various criminal offenses. He ultimately pled guilty to PWID and was sentenced to one to three years of imprisonment. Appellant subsequently waived his right to a parole revocation hearing and admitted that he violated his parole by committing a crime. The Board accepted Appellant’s admission and recommitted him in accord with his original 2011 sentence. The Supreme Court held that the Board abuses its discretion in failing to consider whether to grant CPVs credit for time spent at liberty on parole under the plain language of Subsection 6138(a)(2.1) of the Parole Code, 61 Pa.C.S. sec. 6138(a)(2.1). Additionally, in order to effectuate the intent of the General Assembly in enacting Subsection 6138(a)(2.1), the Court held that the Board must provide a contemporaneous statement explaining its rationale for denying a CPV credit for time spent at liberty on parole. In this case, because the Board’s decision to deny Appellant such credit was based upon its erroneous belief that Appellant was automatically precluded from receiving credit under Subsection 6138(a)(2.1), the Board abused its discretion. View "Pittman v. PA Board of Prob. & Parole" on Justia Law

Appellant Raghunandan Yandamuri, acting pro se, appealed the two death sentences he received after a jury convicted him of two counts of first-degree murder and related offenses for the kidnapping of a ten-month-old baby and the murders of the baby and her grandmother. After reviewing the trial court record, the Pennsylvania Supreme Court concluded the sentence imposed was not the product of passion, prejudice or any other arbitrary factor, but rather was based on the evidence presented at trial. Furthermore, the Court concluded the evidence supported at least one aggravating circumstance for each of the murders committed. The judgment of sentence was therefore affirmed. View "Pennsylvania v. Yandamuri" on Justia Law

Appellant Charles Hicks was tried by jury and convicted of first-degree murder, tampering with evidence, and abuse of a corpse. For these convictions, he received the death penalty. He appealed. The Pennsylvania Supreme Court determined there was sufficient evidence to sustain appellant’s conviction for first degree murder, and his claim regarding Rule 404(b) evidence did not warrant relief. "Our careful review of the record reveals the sentence was not the product of passion, prejudice, or any other arbitrary factor. To the contrary, the sentence was based on properly admitted evidence showing appellant intentionally killed the victim by cutting her throat with a knife. We further conclude the evidence was sufficient to support the aggravating circumstance of killing by means of torture as the Commonwealth expert witnesses testified the victim was severely beaten and strangled before being decapitated while she was still alive. Accordingly, we affirm the judgment of sentence." View "Pennsylvania v. Hicks" on Justia Law

In a discretionary appeal by the Commonwealth, the issue presented for the Supreme Court’s review was whether the presumption that information of public record could not be considered “unknown” for purposes of proving newly-discovered facts exception to the time requirements of the Post Conviction Relief Act (“PCRA”), applied to pro se petitioners who were incarcerated. The Supreme Court held that the presumption did not apply to pro se prisoner petitioners, and so it affirmed the Superior Court’s order remanding the matter to the trial court for further proceedings. View "Pennsylvania v. Burton" on Justia Law

Appellant Bernard Cousar appealed a Court of Common Pleas order denying, without a hearing, the guilt phase claims contained in his petition for relief from his death sentence under the Post Conviction Relief Act (“PCRA”). After review, the Supreme Court remanded this case back to the PCRA court for an evidentiary hearing limited to two issues pertaining to whether trial counsel rendered ineffective assistance for: (1) failing to show the ballistics evidence purportedly tying appellant to a series of crimes and murders was inconsistent; and (2) impeach an eyewitness’s in-court identification of appellant with the witness’s inability to identify appellant at his preliminary hearing. View "Pennsylvania v. Cousar" on Justia Law

In 2007, Junius Burno was convicted on two counts of first-degree murder for which he was sentenced to death. In this direct appeal, Burno challenged the admissibility of his confession to the murders, the sufficiency of the evidence, the alleged denial of his right to a speedy trial, and the admissibility of certain evidence establishing an aggravating factor for purposes of the death penalty. The Supreme Court rejected all but one of these challenges on the merits. The Court found merit to Burno’s argument that one of his statements to police was inadmissible because it was obtained during the course of plea negotiations. However, the Court ultimately concluded that the erroneous admission of this statement at trial was harmless. Consequently, the Court affirmed Burno’s death sentence. View "Pennsylvania v. Burno" on Justia Law