Justia Pennsylvania Supreme Court Opinion Summaries

On April 6, 2011, Shaun Warrick appeared in the Philadelphia Municipal Court for his preliminary hearing on two homicide charges. Appellees were relatives of the victims, and were seated in the courtroom gallery. Before testimony began, Warrick advised the court his mother had retained private counsel for him and requested a continuance. At the court’s request, his mother, escorted by court officer Richard Brandt, came forward to testify. Appellees thereupon verbally and physically assailed Ms. Warrick, and a general melee erupted in the courtroom. Warrick tried to defend his mother, which led to an expanded struggle that required deputy sheriffs and police reinforcements from outside the courtroom to restore order. The courtroom was locked down for three hours. When court reconvened, the trial court did make an “initial finding” of direct criminal contempt but deferred “final determination as to what the sentence should be” until appellees could meet with counsel. Appellees returned to court and sought to present their own witnesses and cross-examine other witnesses. The court denied the requests, finding that appellees were not entitled to call or cross-examine witnesses, particularly as the contemptuous acts took place “in the presence of the [c]ourt.” Appellees appealed, and the three cases were consolidated. Because the Superior Court erroneously determined the summary-contempt proceedings were improper, it also erred in concluding appellees “should have been permitted to cross-examine the court crier, and to present their own witnesses, in an adversary hearing with full due process protections.” The Supreme Court found the trial court appropriately conducted summary proceedings and appellees were sufficiently represented by counsel prior to sentencing. View "Pennsylvania v. Moody" on Justia Law

A jury convicted appellant George Hitcho, Jr. of first degree murder for the death of Freemansburg Police Officer Robert Lasso in 2011. At the penalty phase, the jury found one aggravating circumstance and three mitigating circumstances, unanimously determined the aggravating circumstance outweighed the mitigating circumstances, and sentenced appellant to death. Upon review of the trial court record, the Supreme Court found "no basis upon which to upset the death verdict," and affirmed appellant's conviction and sentence. View "Pennsylvania v. Hitcho" on Justia Law

On the night of March 9, 2001, appellant Stephen Treiber set fire to his home while his girlfriend, Denise Riddle, and his two-year-old daughter, Jessica, slept inside. As the home burned, appellant and Riddle escaped, but Jessica remained in her crib until firefighters removed her; however, they were unable to revive her. Appellant was charged with criminal homicide, reckless endangerment, and multiple counts of arson. Appellant appealed the denial of collateral relief to his criminal convictions and death sentence pursuant to the Post Conviction Relief Act (PCRA). Upon careful consideration of appellant's arguments on appeal and the trial court record, the Supreme Court held that the PCRA court's conclusions were "free from legal error" and supported by the record. Therefore, appellant was not entitled to relief. View "Pennsylvania v. Treiber" on Justia Law

Appellant Shonda Walter was convicted for the 2003 first-degree murder of James Sementelli, for which she received the death penalty. Appellant timely filed a PCRA petition, raising a claim that her appellate attorney had rendered ineffective assistance of counsel in failing to develop the arguments in her brief, as well as numerous other claims. Upon the Commonwealth and Appellant’s consent, the PCRA court granted relief, reinstating Appellant’s right to file a direct appeal nunc pro tunc of the judgment of sentence of death, and thus declined to reach her other claims. Appellant timely appealed to the Supreme Court, raising ten issues, and, after an initial round of briefing, the Court entered an order noting that the trial court had not prepared an opinion in support of its decision to grant Appellant a new direct appeal nunc pro tunc or an opinion concerning Appellant’s issues on appeal, and directing it to do so. After the opinion was prepared, and the Supreme Court reviewed it, the Supreme Court found no reversible error in the lower courts' decisions, and affirmed appellant's conviction and death sentence. View "Pennsylvania v. Walter" on Justia Law

Appellant Richard Laird was convicted for the 1987 killing of Anthony Milano. Appellant and a co-defendant were tried together in May 1988. Each testified and admitted he was present at the crime scene, but blamed the other for the killing. Both defendants were convicted of first-degree murder, kidnapping, aggravated assault, and related offenses. Both were sentenced to death. The Pennsylvania Supreme Court affirmed the sentences. Appellant was unsuccessful in his state application for post-conviction relief; the federal district court granted in part his petition for habeas relief, vacating the first-degree murder conviction and death sentence. With the kidnapping conviction still in place, the Commonwealth retried appellant on the first-degree murder charge in 2007. The jury convicted appellant of first-degree murder, and he was again sentenced to death. Appellant filed an amended PCRA petition, raising thirteen claims. The PCRA court dismissed two claims without a hearing; the remainder were dismissed after a hearing in which a number of witnesses testified. Appellant appealed the PCRA's dismissal of his claims, principally arguing he received ineffective assistance of trial counsel, and the cumulative effect of counsel's alleged errors were grounds for relief. Finding no reversible error, the Supreme Court affirmed appellant's conviction and death sentence. View "Pennsylvania v. Laird" on Justia Law

Appellant Andre Staton was convicted in 2006 for the first degree murder of his girlfriend, for which he received the death sentence. The sentence was affirmed on direct appeal, and he applied for collateral relief pursuant to the Post Conviction Relief Act (PCRA). The PCRA court denied the petition without a hearing, and appellant appealed that denial to the Supreme Court. Because the Supreme Court concluded the PCRA court's findings were supported by the record and that there were no reversible errors in that court's conclusions, the denial of post-conviction relief was affirmed. View "Pennsylvania v. Staton" on Justia Law

In this capital case, the United States District Court for the Western District of Pennsylvania held that Appellant Scott Wayne Blystone was entitled to receive a new sentencing hearing after concluding that his counsel was ineffective for failing to investigate and develop penalty-phase mitigating evidence in the form of institutional records and expert mental-health evidence. The United States Court of Appeals for the Third Circuit affirmed, and Appellant the new penalty-phase hearing was pending following the completion of discovery. Throughout the course of counsel’s current mitigation investigation, Appellant’s mother, Norma Blystone, refused to divulge certain "critical" information regarding Appellant’s childhood unless she was assured that the information she provided would not be made public. In an attempt to provide Mrs. Blystone with such assurances and to obtain this additional information from her, Appellant filed a motion for limited courtroom closure and temporary sealing of transcripts with respect to Mrs. Blystone’s testimony, any expert testimony addressing the information Mrs. Blystone might reveal, and any closing arguments referencing such testimony. The trial court denied the motion, and Appellant filed an interlocutory appeal. After review, the Supreme Court concluded that it lacked jurisdiction to review the trial court’s interlocutory order denying Appellant’s closure motion, and, accordingly, this appeal was quashed. View "Pennsylvania v. Blystone" on Justia Law

The Commonwealth appealed the Philadelphia Court of Common Pleas' granting of appellee Edward Bracey’s Post Conviction Relief Act (PCRA) petition. The court determined appellee suffered from an intellectual disability, and vacated his death sentence. After review of the specific facts of this case, the Pennsylvania Supreme Court found no reversible error in that decision, and affirmed. View "Pennsylvania v. Bracey" on Justia Law

In 2009, two girls were sexually assaulted. Sixteen-year-old C.J. escaped, but eleven-year-old N.O. was threatened and lured into an alleyway, where she was brutally raped and sustained severe injuries requiring hospitalization and surgery. Police investigated and arrested Appellee Jose Carrasquillo, who made inculpatory statements during interrogation. Charges were lodged in two separate criminal proceedings, which were later consolidated for trial. Appellee decided to enter open guilty pleas to various sexual offenses, including rape, as well as other crimes. At the plea colloquy, the Commonwealth proffered that the evidence against Appellee that included his own statements, identification testimony from both victims, video surveillance recordings apparently showing Appellee with or in the vicinity of each victim close in time to the assaults, and DNA and fingerprint evidence linking Appellee to the rape of N.O. The plea court advised Appellee of his pertinent constitutional rights and the implications of waiver. The plea court accepted appellee's pleas and entered verdicts. Appellee was also informed that he could seek to withdraw his guilty plea at any time before sentencing and that the court "would have to consider whether or not the reasons for you doing so are fair and necessary, fair and appropriate, compared to the prejudice that that might cause to the Commonwealth's case and to their witnesses, and particularly in this case to child witnesses." Three and a half months later, the court conducted a sentencing hearing. After the defense rested, Appellee explained in allocution that he had pled guilty to spare N.O. suffering, and he therefore expressed surprise at his portrayal during the sentencing hearing. Appellee also stated that he had entered his plea because, absent a polygraph examination, his account would not have been believed and he would not have received a fair trial. In this appeal, the issue this case presented for the Supreme Court's review centered on the criteria governing the disposition of a presentence motion to withdraw a guilty plea. The Court's decision turned on the conclusion that a bare assertion of innocence was not, in and of itself, a sufficient reason to require a court to grant such a request. The Court was persuaded by the approach of other jurisdictions: "the proper inquiry on consideration of such a withdrawal motion is whether the accused has made some colorable demonstration, under the circumstances, such that permitting withdrawal of the plea would promote fairness and justice. The policy of liberality remains extant but has its limits, consistent with the affordance of a degree of discretion to the common pleas courts. This case, in our view, illustrates why the existing per se approach to innocence claims is unsatisfactory." In this case, the Supreme Court found that the trial court acted within its discretion to refuse the attempted withdrawal of the plea. View "Pennsylvania v. Carrasquillo" on Justia Law

This appeal was a companion case with "Pennsylvania v. Carrasquillo." The issue presented centered on whether a common pleas court was required to permit withdrawal of a guilty plea, upon the defendant-appellee's assertion of innocence. Appellee stabbed his estranged wife, Kimberly, to death. He immediately surrendered to police and confessed. Subsequently, he pled guilty to first-degree murder and possession of an instrument of crime. In exchange for the plea, the Commonwealth was to recommend that Appellee would receive the mandatory sentence of life imprisonment for first-degree murder and a consecutive term of incarceration pertaining to the possessory offense. Just over two months later, when Appellee appeared for sentencing, he advised the court that he wished to withdraw his plea. In "Carrasquillo," the Pennsylvania Supreme Court determined that a bare assertion of innocence (such as Appellee provided as the basis for withdrawing his guilty plea) was not, in and of itself, a sufficient reason to require a court to grant such a request. Accordingly, and for the reasons set forth more fully in that case, the common pleas court did not err in denying Appellee's withdrawal motion. View "Pennsylvania v. Hvizda" on Justia Law