Justia Pennsylvania Supreme Court Opinion Summaries

In a discretionary appeal by the Commonwealth, the Supreme Court considered whether Appellee Claude Descardes was entitled to seek review of his ineffectiveness of counsel claim, based on counsel’s failure to advise him of the collateral consequences of his guilty plea, via a petition for writ of coram nobis. Appellee, a Haitian national who held resident alien status in the United States, pled guilty to insurance fraud, a felony, and conspiracy to commit insurance fraud. Appellee was not advised prior to entering his plea that deportation was a collateral consequence of his plea pursuant to the Immigration and Naturalization Act. Appellee was sentenced to one year of probation and a fine, and did not appeal his judgment of sentence. He completed serving his probationary sentence in November 2007. In 2009, Appellee left the United States on personal business and, when he attempted to reenter the country, United States immigration officials denied him reentry due to his felony convictions. After review, the Supreme Court concluded that Appellee was not entitled to seek review of his ineffectiveness of counsel claim, and accordingly vacated the Superior Court's judgment holding to the contrary. Appellee's underlying petition for postconvicton relief was dismissed. View "Pennsylvania v. Descardes" on Justia Law

In July 2004, Appellant James Vandivner fatally shot his fiancee, Michelle Cable, for which he received the death penalty. Appellant appealed the denial of his petition for post-conviction relief, raising claims pertaining to his pre-trial, guilt, and penalty-phase proceedings. The PCRA court, having concluded Appellant’s claim did not have arguable merit, did not fully address Appellant's ineffectiveness of counsel claims. The Supreme Court concluded this omission required further review. It vacated the PCRA court’s order and remanded this matter back to the PCRA court for preparation of a supplemental opinion addressing whether any reasonable basis existed for trial counsel’s failure to investigate certain aspects of Appellant's ineffectiveness claims. View "Pennsylvania v. Vandivner" on Justia Law

The Pennsylvania Supreme Court affirmed the death sentence for Richard Poplawski, convicted in 2011 of killing three Pittsburgh police officers. The officers were killed on April 4, 2009, when they responded to Poplawski's home for a domestic dispute with his mother. Poplawski, armed with multiple weapons, thousands of rounds of ammunition and body armor launched a gunfight with the city that lasted for hours. "The record shows that the jury balanced three aggravating circumstances against two statutory mitigating circumstances and determined that the aggravating circumstances outweighed the mitigating circumstances. Therefore, there exists no ground to vacate the sentence." View "Pennsylvania v. Poplawski" on Justia Law

Appellant Lenwood Mason's convictions arose from the June 1994, stabbing death of Iona Jeffries, for which he received the death penalty. His first Post-Conviction Relief Act petition was dismissed, and he appealed. Appellant contended that the cumulative effect of errors committed by the trial court and trial counsel’s ineffectiveness prevented the jury from hearing important evidence relevant to making its guilt phase and sentencing determinations. He raised eleven claims of error on appeal to the Supreme Court. With respect to issues one through six, and eight through eleven, the Supreme Court affirmed the PCRA court. In issue seven, Appellant's PCRA petition was pending when the U.S. Supreme Court decided "Atkins v. Virginia," (536 U.S. 304 (2002)). With respect to issue seven, Appellant argued that under Atkins, he was ineligible for the death penalty, and that the PCRA court erred in permitting Appellant acting pro se (over trial counsel's objection), to "waive" this claim. The Supreme Court found that, "where confronted with neither a basic, fundamental decision concerning Appellant’s PCRA challenge nor disagreement between counsel and Appellant with respect to the overarching objectives of the challenge, the PCRA court erred in ruling that counsels’ authority to seek an Atkins hearing was subject to Appellant’s veto. Furthermore, by acting directly on Appellant’s pro se letter moving for the court to accept his waiver of the counseled Atkins claim, the PCRA court impermissibly invited hybridized representation." The Supreme Court reversed on issue seven and remanded this case for further proceedings. View "Pennsylvania v. Mason" on Justia Law

In 2011, Heather Forsythe and Appellant Patrick Haney presented at Ruby Memorial Hospital in Morgantown, West Virginia with Forsythe’s four-year-old son, Trenton Lewis St. Clair. When Trenton arrived, he had neither a pulse nor signs of life. Forsythe and Appellant told emergency personnel that Trenton had fallen down a flight of stairs. Attempts to resuscitate the boy were unsuccessful, and he was pronounced dead shortly after arriving at the hospital. An examining physician's testimony at trial stated that it was “immediately evident that the child had been beaten. He was covered in bruises. There was blood around his mouth.” Forsythe gave a written statement to police explaining that she had observed Appellant physically abusing Trenton. Appellant would later be charged with first-degree murder and child endangerment. He ultimately received the death penalty for these crimes. His appeal to the Pennsylvania Supreme Court was automatic. After review, the Court concluded all of appellant's claimed of error at trial were meritless, and it affirmed his conviction and sentence. View "Pennsylvania v. Haney" on Justia Law

The Supreme Court granted certiorari review in this matter to address divergent decisions in the lower courts pertaining to the statutory scheme governing chemical testing of persons suspected of DUI and related traffic offenses. The Commonwealth Court has consistently construed the “Implied Consent Law” at 75 Pa.C.S. 1547 to require a motorist to assent unequivocally to an official request to take whichever statutorily-prescribed chemical test police select "on pain of" automatic license suspension, whereas the Superior Court has determined a motorist’s compliance with the law if he responds to the official request by asking to take a reasonably practicable, prescribed test of his choosing. The issue presented by the lower court analyses for the Supreme Court's review was, specifically, whether a motorist who requests an alternative test to the officer’s preferred test exercises a statutory right or, instead, refuses to submit to chemical testing in violation of the Implied Consent Law so as to incur suspension of his operating privileges. The Supreme Court found no right to alternative chemical testing in Section 1547. In this case, Appellant's request for alternative chemical testing instead of the test offered by the officer at the moment of his arrest constituted a refusal under the Implied Consent law, and the Commonwealth Court was correct in its analysis appellant's DUI conviction under the Law. View "Nardone v. Dept of Transportation" on Justia Law

Appellant Wayne Smith was given a death sentence for his role in the 1994 strangulation of Eileen Jones. Appellant raised several alleged errors by the trial court that warranted reversal of the death sentence and for a new trial. Finding no reversible error, the Supreme Court affirmed appellant's judgment of sentence. View "Pennsylvania v. Smith" on Justia Law

In 2003, a jury convicted Raymond Solano of first-degree murder for the shooting death of his victim, who was playing basketball in a crowded park. After shooting victim repeatedly, Solano fled, but then turned around and shot toward the crowded park where victim lay; several casings were recovered from adjacent streets, and one bullet entered a nearby home. The Commonwealth appealed the order granting Solano relief post-conviction relief in the form of a new penalty phase, based on trial counsel’s ineffectiveness for failing to present sufficient mitigating evidence. Solano cross-appealed the portion of the same order denying him guilt-phase relief. Finding no reversible error, the Supreme Court affirmed the trial court's judgments. View "Pennsylvania v. Solano" on Justia Law

This case presented the issue of whether Governor Tom Wolf exceeded his constitutional authority pursuant to Article IV, Section 9(a) of the Pennsylvania Constitution when he issued a temporary reprieve to death row inmate Terrance Williams pending receipt of the forthcoming report of the Pennsylvania Task Force and Advisory Committee on Capital Punishment (Task Force) and until the concerns raised by the Task Force are addressed. Respondent Terrance Williams was convicted of first degree murder after he robbed and beat Amos Norwood to death with a tire iron in 1984. He was subsequently sentenced to death. On January 13, 2015, Governor Tom Corbett signed a death warrant scheduling Williams’ execution for March 4, 2015. Shortly after the death warrant was signed, Governor Tom Wolf assumed office and, on February 13, 2015, issued a reprieve of Williams’ death sentence. On the same day, Governor Wolf issued a Memorandum, explaining that he granted Williams’ reprieve because he believed that “the capital punishment system has significant and widely recognized defects.” Five days later, on February 18, 2015, the District Attorney of Philadelphia (Commonwealth) filed an Emergency Petition for Extraordinary Relief Under King’s Bench Jurisdiction, naming Respondent Williams as the opposing party, arguing that Governor Wolf was attempting to negate a criminal penalty applicable to an entire class of cases (i.e., first degree murder cases where the death penalty was imposed) based on his personal belief that Pennsylvania’s death penalty apparatus is flawed. The Commonwealth argued that the Pennsylvania Constitution did not permit the Governor to grant the purported reprieve for purposes of establishing a moratorium on the death penalty. The Supreme Court indeed exercised its King’s Bench authority to review the issue presented and concluded that Governor Wolf acted within his constitutional authority in granting the reprieve. View "Pennsylvania v. Williams" on Justia Law

The Commonwealth appealed a Superior Court’s order finding appellee Raymond Farabaugh was not required to register as a sexual offender. In 2011, appellee pled guilty to indecent assault, graded as a second-degree misdemeanor. The trial court sentenced him to two years probation; at the time of sentencing, the law did not require appellee to register as a sexual offender. Later that year, amendments to Megan’s Law added crimes to the list defined as sexually violent offenses, and established a three-tiered system for classifying such offenses and their corresponding registration periods. The 2011 amendments became effective December 20, 2012; they applied to individuals who, as of that date, were convicted of a sexually violent offense and were incarcerated, on probation or parole, or subject to intermediate punishment. Appellee was subject to the reporting and registration requirements, and, as a Tier-II sexual offender, was required to register for 25 years. After Megan’s Law IV went into effect, appellee filed a “Petition to Enforce Plea Bargain/Habeas Corpus,” arguing that ordering him to comply with the new registration and reporting requirements violated his plea agreement and various state and federal constitutional provisions. The trial court denied the petition, and appellee appealed to the Superior Court. On March 14, 2014, while the appeal was pending and after the parties had submitted their briefs, the governor signed Act 19 into law, amending the provisions of Megan’s Law again; the Act was effective immediately and made retroactive to December 20, 2012. The Superior Court panel sua sponte addressed Act 19, holding the above language exempted appellee from the requirements of Megan’s Law. Finding that the Superior Court's holding was made in error, the Supreme Court reversed and the case remanded for further proceedings. View "Pennsylvania v. Farabaugh" on Justia Law