Justia Pennsylvania Supreme Court Opinion Summaries

In the summer of 1993, Christopher Williams and two codefendants, Theopolis Wilson (also referred to as “Binky” at trial) and Rick Bennett, appeared before a jury, each facing numerous charges related to the shooting deaths of Philadelphia cabdriver William Graham and three young men from New York, Otis Reynolds, Gavin Anderson and Kevin Anderson. James White, a purported eyewitness and accomplice to the murders, testified that Reynolds and the Anderson brothers were in Philadelphia to purchase two AK-47s from Williams. According to White, Williams was the leader of a gang that sold drugs and guns; White was a junior member. Unbeknownst to the victims, the arms deal was a ruse, and Williams planned to rob them when they met. On August 6, 1993, the jury convicted Williams of three counts of first-degree murder and related offenses for which he received three consecutive death sentences. Williams subsequently filed a timely PCRA petition raising twenty-four claims. Relevant here, Williams asserted therein that trial counsel was ineffective for failing to properly cross-examine the Commonwealth’s experts or call a forensic expert in defense, as the physical evidence did not align with White’s testimony about how the shootings occurred and their aftermaths. Before the Supreme Court were two appeals: the Commonwealth's appeal of the order entered by the Philadelphia County Court of Common Pleas granting Williams a new trial pursuant to the Post Conviction Relief Act; and Williams' protective cross-appeal challenging various unfavorable determinations made by the PCRA court on other claims he raised in his PCRA petitions. After careful review, the Court concluded that the record and the law supported the PCRA court’s findings that direct appeal counsel rendered ineffective assistance to Williams, and therefore affirmed. View "Pennsylvania v. Williams" on Justia Law

When 20-years-old, appellant Victoria Giulian was arrested and ultimately pled guilty to summary public drunkenness and harassment. At the same time, she was charged with misdemeanor disorderly conduct (later withdrawn) and underage drinking. To the two misdemeanors, appellant pled guilty. Approximately a year later, appellant was arrested and pled guilty to summary criminal mischief. Between 1998 and 2013, appellant had no arrests. She subsequently filed a petition seeking expungement of the summary convictions from her criminal history. The Commonwealth did not object to expungement of the withdrawn disorderly conduct charge and the guilty plea conviction for underage drinking, and the record of these charges was expunged. The Commonwealth did oppose expungement with respect to the other offenses. The Centre County Court of Common Pleas granted the petition with regard to the 1998 criminal mischief conviction, but denied expungement of the records relating to the 1997 public drunkenness and harassment convictions. The court acknowledged appellant was “conviction free for 16 years” after 1998, but determined appellant was not entitled to expungement of the earlier convictions because her 1998 arrest and plea meant she did not remain free of arrest or prosecution for “at least five years following the 1997 convictions” as required by 18 Pa. C.S. subsection (b)(3)(i). The Supreme Court considerd the statutory requirements for expungement of criminal history record information for summary convictions pursuant to 18 Pa.C.S. 9122(b)(3) and concluded the lower courts erred in holding expungement unavailable as a matter of law in this matter. The Court therefore reversed and remanded for further proceedings. View "Pennsylvania v. Giulian" on Justia Law

Appellant Ryan Safka was the driver of an automobile that crashed killing three of his four passengers. The investigating police officer believed that Appellant’s speed caused the accident. He, in part, relied upon data retrieved from the vehicle’s Event Data Recorder (EDR) which recorded the vehicle’s speed for the five seconds prior to the airbag’s deployment. In his vehicular manslaughter bench trial, after the evidence was closed, the trial court reopened it to permit the parties to present additional evidence concerning the reliability of the EDR data. The question this case presented for the Pennsylvania Supreme Court's review was whether the trial court erred in reopening evidence. The Court held that because it was a non-jury trial, the trial court had the discretion to reopen the record sua sponte to receive additional testimony to avoid a miscarriage of justice, and did not abuse its discretion by doing so. View "Pennsylvania v. Safka" on Justia Law

In August 2012, Appellee Matthew Wolfe, then eighteen years old, engaged in sexual intercourse with a thirteen-year-old girl on several occasions. He was charged with and convicted by a jury trial for a number of sexual offenses, including two counts of involuntary deviate sexual intercourse. During Appellee’s trial and prior to sentencing, the United States Supreme Court issued its "Alleyne v. United States," (133 S. Ct. 2151 (2013)) decision, overruling its own prior precedent and establishing a new constitutional rule of law, grounded on the Sixth Amendment to the United States Constitution. The Pennsylvania Supreme Court allowed appeal in Wolfe's case to assess the validity of the Superior Court’s sua sponte determination that a sentencing statute was facially unconstitutional under Alleyne. "We are not unsympathetic to the plight of the Commonwealth in Alleyne’s wake, given the volume of the mandatory minimum sentences that must be stricken, and the scale of the task of resentencing. We also appreciate that, in enacting the mandatory minimum sentencing regime, the General Assembly had acted in good faith reliance on the previous jurisprudence of the Supreme Court of the United States, which was discarded by that Court in Alleyne. Nevertheless, new constitutional rules of Alleyne’s magnitude often have unavoidable, wide-scale consequences." Accordingly, the Court affirmed the Superior Court's decision. View "Pennsylvania v. Wolfe" on Justia Law

In a direct appeal, the issue presented for the Pennsylvania Supreme Court's review involved a challenge to the regularity of the enactment of Act 192 of 2014. Act 192 began as House Bill 80 (“HB 80”), introduced in January 2013. Initially, HB 80 was a two-page bill which added the newly-defined offense of theft of secondary metal (such as copper and aluminum, or wire and cable used by utilities and transportation agencies) to the Crimes Code at Section 3935. The bill was titled, “AN ACT Amending Title 18 (Crimes and Offenses) of the Pennsylvania Consolidated Statutes, defining the offense of theft of secondary metal; and prescribing penalties.” After undergoing minor revisions, HB 80 was approved by the House and sent to the Senate. The Senate Judiciary Committee added a section amending the existing trespass provision of the Crimes Code to specify that an individual who trespasses in order to steal secondary metal commits a first-degree misdemeanor as a “simple trespasser.” Meanwhile, in April 2013, a separate House bill, HB 1243, was introduced and began proceeding through the General Assembly. HB 1243 changed various provisions of subchapter 61(A) of the Crimes Code, (the Pennsylvania Uniform Firearms Act of 1995). As amended on its second consideration in the House, the bill retained some of its original provisions and, important to this dispute, encompassed substantial additions to Section 6120, which generally prohibited counties and other municipalities from regulating the lawful ownership, possession, transfer, or transportation of firearms and ammunition. On October 15, 2014, HB 1243’s substantive provisions were folded into HB 80. The Supreme Court concluded that Act 192 violated the single-subject rule of Article III, Section 3 of the Pennsylvania Constitution. View "Leach v. Turzai" on Justia Law

Appellant Antyane Robinson appealed the PCRA court's denial as untimely his second petition for relief. Acknowledging that current Pennsylvania jurisprudence renders his petition time-barred, Appellant requested that the Pennsylvania Supreme Court create an equitable exception to the PCRA’s timeliness requirements. The Court declined Appellant’s invitation and affirmed the PCRA court’s dismissal of his petition as untimely filed. View "Pennsylvania v. Robinson" on Justia Law

In 2008, Appellant Omar Cash shot and killed Muliek Brown at a car wash in Philadelphia. The shooting was caught on the carwash’s surveillance video, which showed Brown cleaning the tire rims of his car and Appellant approaching him from behind and shooting him in the back of the head. Following the shooting, Appellant fled the scene, and Robert Green, a carwash employee who watched the shooting take place on a monitor inside the carwash’s office, called 911. As one police officer secured the scene, his partner, Officer Pross, was approached by Marcus Howard, who indicated that he saw a light-complexioned male with a “Muslim beard” and wearing a black hoodie and Capri shorts, consistent with Appellant’s appearance, flee the scene. Officers would ultimately secure Appellant's arrest in New York City; he was extradited back to Philadelphia where he was charged with first-degree murder. Appellant would be convicted by jury and sentenced to death. He raised several alleged errors warranting the overturn of his conviction. Finding none, the Supreme Court affirmed. View "Pennsylvania v. Cash" on Justia Law

Robert Anthony Flor petitioned for post-conviction relief, alleging ineffective assistance of counsel at his trial for homicide. After two years of proceedings in the PCRA court, the Commonwealth moved for the production of documents, requesting “access to the complete records” of trial counsel. This file included some 30,000 pages of documents pertaining to Flor’s conviction, sentence, and direct appeal, and filled twelve banker’s boxes. At a hearing on the Commonwealth’s motion, Flor’s PCRA counsel requested several weeks to review the file to allow removal of material protected by attorney-client privilege or constituting attorney work product. The PCRA court granted the Commonwealth’s motion and denied PCRA counsel’s request for time to conduct a privilege review. Flor appealed the discovery order. After review, the Supreme Court concluded that the PCRA court’s discovery order was immediately appealable, and that the PCRA court abused its discretion in affording wholesale discovery without conducting an issue-specific waiver analysis, as required by "Commonwealth v. Harris," (32 A.3d 243 (Pa. 2011)). Accordingly, the Court vacated the discovery order, and remanded for immediate inspection of the file. View "Pennsylvania v. Flor" on Justia Law

Appellant Laquanta Chapman shot and killed his sixteen-year-old neighbor in the basement of Appellant's home. Subsequently, with the assistance of his younger cousin, Bryan Bird, Appellant dismembered the victim’s body and disposed of the remains in the trash. Weeks later, law enforcement officers investigating the sale of illicit drugs from Appellant’s premises obtained a warrant to search them for evidence of drug activity. In the course of the ensuing search, police discovered an abundance of residual, physical evidence from the killing and dismemberment. Appellant was arrested and charged with murder and other crimes. The jury convicted Appellant of first-degree murder and other offenses and returned a death verdict in a separate penalty proceeding. Post-sentence motions were filed and denied, and this direct appeal followed. Appellant presented several claims of trial court error at the penalty stage, arguing primarily that the evidence offered by the Commonwealth in support of the sole aggravating circumstances pursued by the prosecution and found by the jury was insufficient. View "Pennsylvania v. Chapman" on Justia Law

Appellant Kevin Murphy was convicted by jury for the first-degree murder of his mother, sister and aunt. This case went before the Pennsylvania Supreme Court on direct appeal. Three of the five challenges to the judgment of sentence raised by Appellant centered on the adequacy of the Commonwealth’s evidence of his guilt. He also argued that the trial court erred in not suppressing certain evidence from trial. In Appellant’s final argument, he asserted that, because the aggravating circumstances found by the jury in the penalty proceedings overlapped, the jury impermissibly “double-count[ed]” the aggravation. Finding no reversible error as to any of Appellant's claims, the Supreme Court affirmed his death penalty. View "Pennsylvania v. Murphy" on Justia Law