Justia Pennsylvania Supreme Court Opinion Summaries

The Pennsylvania Supreme Court granted review to consider whether appellant was subject to custodial interrogation during an encounter with parole agents, such that their failure to issue Miranda1 warnings violated his Fifth Amendment rights. The Superior Court held that Miranda warnings were not required during questioning by the parole agents because appellant's statements were merely part of a parole interview rather than a custodial interrogation. It noted custody was equivalent to "a formal arrest or restraint on freedom of movement of the degree associated with a formal arrest." The court reviewed various factors and found the mere fact appellant was handcuffed was insufficient to show he was arrested. Appellant argued to the Supreme Court that the parole agent should have issue Miranda warnings to a parolee when he was in custody and questioned about new crimes. Under the facts of this case, the Supreme Court agreed that appellant was subject to custodial interrogation such that his parole agents' failure to issue Miranda warnings violated his Fifth Amendment rights, and the courts below erred in failing to suppress his incriminating statements, and such error was not harmless. Thus, appellant was entitled to a new trial consistent with the guidelines the Court set out in this opinion. View "Pennsylvania v. Cooley, III" on Justia Law

The issue this case presented for the Supreme Court's review centered on the constitutionality and severability of 18 Pa.C.S. section 6317(a), which imposed a mandatory minimum sentence of two years total confinement upon a defendant for a conviction if a delivery or possession with intent to deliver a controlled substance occurs within 1,000 feet of, inter alia, a school in light of the United States Supreme Court's decision in "Alleyne v. United States," (133 S. Ct. 2151 (2013)). In 2013, the Pennsylvania State Police filed a criminal complaint against Appellee Kyle Hopkins, charging him with various violations of the Controlled Substance, Drug, Device and Cosmetic Act. The charges arose from three incidents which took place over three days in April 2012, during which Appellee sold heroin to a confidential informant in Kennett Square Borough and New Garden Township, Chester County. One sale allegedly occurred in a school zone. Appellee was held for court on all charges stemming from those instances, in all, Appellee had 12 counts against him. The trial court reasoned that it was bound by the United States Supreme Court's decision in "Alleyne," and granted Appellee's Motion for Extraordinary Relief. The Commonwealth appealed. After review, the Pennsylvania Supreme Court affirmed, holding that numerous provisions of Section 6317 were "constitutionally infirm" under Alleyne. Moreover, the remaining provisions of Section 6317, standing alone, were incomplete and "incapable of being vindicated in accord with the intent of the General Assembly." Because of the significant provisions found to violate the Constitution and the remaining unoffending provisions of Section 6317 were incapable of being severed. The Court declined to "rewrite Section 6317 or create a substantive offense which the General Assembly clearly did not desire." View "Pennsylvania v. Hopkins" on Justia Law

This appeal centered on the nature of a valid invocation of the Miranda-based right to counsel, specifically, in terms of whether the right must be asserted in close temporal proximity to custodial interrogation or may be effectively invoked remotely from such questioning. Appellee Dennis Bland, Jr. allegedly shot and killed Keron Remberan in Philadelphia, then fled to his mother’s house in Florida. After learning of Appellee’s whereabouts, police obtained an arrest warrant and notified Florida law enforcement. Federal authorities in Florida detained Appellee, who was seventeen years old at the time, and he was placed in a juvenile facility to await extradition to Pennsylvania. The day after Appellee’s arrest, his father contacted the Defender Association of Philadelphia and apprised an attorney of his son’s circumstances. The lawyer sent a form letter via facsimile to Florida counsel representing Appellee in connection with the extradition proceedings, asking that Appellee sign and return the document. The letter reflected a very clear putative invocation of the Miranda-based right to counsel. Six days after Appellee had signed the form sent by the Defender Association while he was in Florida, a detective provided him with Miranda warnings. During ensuing questioning, Appellee ultimately confessed to perpetration of the killing, and, after later consultation with his father, he also provided a written confession. Appellee was charged with murder, firearms violations, and several related offenses, and the Defender Association was formally appointed as counsel. Appellee filed a pre-trial motion to suppress his written statement, claiming that police violated his rights under Miranda, as well as under Article 1, Section 9 of the Pennsylvania Constitution. The Supreme Court held that, to require a suspension of questioning by law enforcement officials on pain of an exclusionary remedy, an invocation of the Miranda-based right to counsel must be made upon or after actual or imminent commencement of in-custody interrogation. View "Pennsylvania v. Bland" on Justia Law

Following a jury trial on charges that he endangered the welfare of children, appellee William Lynn was convicted and sentenced to a term of three to six years of incarceration. On appeal, he challenged the sufficiency of the evidence, arguing that he had no direct supervision of the children he was found to have endangered. The Superior Court agreed, and reversed his conviction. On the Commonwealth’s appeal, the Supreme Court reversed the Superior Court, concluding that there was no statutory requirement of direct supervision of children. "Rather, that which is supervised is the child’s welfare. Under the facts presented at trial, Appellee was a person supervising the welfare of many children because, as a high-ranking official in the Archdiocese of Philadelphia, he was specifically responsible for protecting children from sexually abusive priests." View "Pennsylvania v. Lynn" on Justia Law

Appellant Noel Montalvo was the brother of Milton Montalvo. Milton was convicted of the 1999 murder his common-law wife Miriam Ascensio. Appellant would later be charged as being an accomplice to the murder. More than three years after Milton was convicted of two counts of first-degree murder for the deaths of Miriam and Nelson, a jury convicted Appellant of first-degree murder for the death of Miriam, second-degree murder for the death of a friend of Miriam's, Nelson Lugo, conspiracy to commit murder, and burglary. Appellant applied for post-conviction relief, listing eleven alleged errors at trial that ultimately entitled him to relief. "As a result of the PCRA court’s failures, [the Pennsylvania Supreme] Court has no findings of fact, no determinations of credibility, and no legal conclusions regarding Appellant’s PCRA claims; in short, [the Court had] no basis upon which to conduct meaningful appellate review." The Court vacated the PCRA court's judgment, and remanded the case for further proceedings. View "Pennsylvania v. Montalvo" on Justia Law

In July 2012, claimant Charles Chamberlain was unemployed and was receiving unemployment compensation benefits. In October, he pled guilty to the summary offenses of operating a vehicle without a valid inspection, and driving with a suspended license. Relating to the latter conviction, Claimant was sentenced to sixty days in the Keystone House Arrest Program (from November 1, 2012 to December 31, 2012) with the condition that if he failed to comply, he would serve sixty days in the York County Prison. Claimant was also required to attend reemployment eligibility assessment classes. The terms of Claimant’s house arrest restricted him to the home of his sister, but permitted him to work, run errands, and do his Christmas shopping. On November 28, 2012, the local service center of the Office of Unemployment Compensation Benefits issued a notice of determination that Claimant’s sentence of house arrest disqualified him from receipt of benefits because he was “incarcerated after a conviction” under Section 402.6. Claimant appealed the finding of disqualification and, in 2013, a hearing was held before a referee for the Unemployment Compensation Board of Review (UCBR). The referee concluded Claimant was disqualified from receiving benefits, and Claimant appealed. Mindful of the remedial purpose of the Unemployment Compensation (UC) Law, the Commonwealth Court held that a claimant sentenced to house arrest is not “incarcerated” under Section 402.6. Because the terms and conditions of the claimant’s house arrest did not otherwise prevent him from satisfying the statutory requirements for obtaining unemployment compensation benefits, the Commonwealth Court reversed the denial of benefits. Agreeing with the Commonwealth Court's conclusion, the Supreme Court affirmed. View "Chamberlain v. Unemployment Compensation Review Bd." on Justia Law

The Post Conviction Relief Act (PCRA) court, after a hearing, rendered an opinion in which it resolved several issues on remand from the Supreme Court. Pertinent to this appeal, the issue was whether appellant received ineffective assistance of trial counsel, and was therefore entitled to relief. With the remand proceedings complete, the Supreme Court considered the issue of whether appellant was entitled to relief based on the cumulative prejudicial effect of all of the alleged errors he set forth in his petition. The Court held that the PCRA court properly resolved the ineffectiveness claims before it, and the Supreme Court concluded that appellant was not entitled to relief on his claim of cumulative prejudice. Thus, the Court affirmed the order of the PCRA court and dismissed all of appellant's claims. View "Pennsylvania v. Simpson" on Justia Law

After state police seized over two and one-half pounds of marijuana from appellee Dreama Stotelmyer's residence pursuant to a search warrant, she was charged with possession of a controlled substance with intent to deliver (PWID) and possession of drug paraphernalia. Appellee entered an open guilty plea to PWID, and the Commonwealth nolle prossed the remaining charge. After entry of the plea, the Commonwealth entered notice of its intent to seek application of the mandatory minimum one-year sentence of incarceration. After a hearing, the trial court determined the Commonwealth proved by a preponderance of the evidence that appellee possessed over two pounds of marijuana with the intent to distribute it, invoking 18 Pa.C.S. 7508's mandatory minimum sentencing provisions. However, the trial court instead sentenced appellee to county intermediate punishment, imposing six months of work release from the county jail followed by six months of electronic home monitoring. Following the denial (by operation of law) of its motion to modify sentence, the Commonwealth appealed to the Superior Court, and then to the Supreme Court. The Supreme Court, after review, concluded the Superior Court erred in holding that appellee was eligible for the intermediate punishment sentence when the mandatory minimum sentence under 18 Pa.C.S. 7508 applied. View "Pennsylvania. v. Stotelmyer" on Justia Law

In this capital case, Herbert Blakeney, a.k.a. Shabazz Muhammad, appealed a Court of Common Pleas order that denied his petition for relief under the Post Conviction Relief Act (“PCRA”) without a hearing. Blakeney was convicted for the stabbing deaths of his wife and her 14-month old son in the early morning hours of February 2, 2000. After careful consideration of Blakeney's arguments on appeal, the Supreme Court found that the PCRA court properly dismissed his petition for post-conviction relief without a hearing. View "Pennsylvania v. Blakeney" on Justia Law

Appellant Gerald Watkins appealed the denial of his petition for post-conviction relief, which was filed after the Supreme Court’s affirmed his direct appeal from three death sentences imposed following his conviction for murdering his girlfriend, their newborn daughter, and his girlfriend’s son. Finding that the PCRA court did not err in denying appellant relief, the Supreme Court affirmed that court's decision. View "Pennsylvania v. Watkins" on Justia Law