Justia Pennsylvania Supreme Court Opinion Summaries

While arguing with his wife, appellant struck her, knocked her to the ground, and attempted to force her back into their home; she escaped and drove to the police station. Police charged appellant with harassment and simple assault. While in prison awaiting his preliminary hearing, appellant tried to call his wife multiple times; she did not answer because the calls upset her. On time, appellant called his father, who called appellant’s wife on a separate phone and relayed appellant’s statements to her, establishing a three-way call on the two phones. Appellant insisted his wife tell the magistrate she would not testify, that she made a mistake, and that she caused her own injuries. If she failed to do so, appellant stated he would go to jail for two years, starve, and lose everything. He also told her that she must comply for the sake of their marriage, which he repeatedly described as “priceless.” Appellant stated that if his wife was charged with making false statements, he would pay her fines. Two days later, she told police she no longer wished to press charges. In light of the phone call, the Commonwealth charged appellant with intimidation of a witness under 18 Pa.C.S. 4952. A jury convicted appellant of simple assault and intimidation of a witness, and the trial court convicted him of harassment. He was sentenced to an aggregate term of 33 to 66 months imprisonment. Appellant appealed the Superior Court order affirming his conviction, requesting that the Supreme Court overrule or clarify “Commonwealth v. Brachbill,” (555 A.2d 82 (Pa. 1989)). “‘Brachbill’ did not abolish the Commonwealth’s need to prove intimidation. Whether an offer of a pecuniary or other benefit contains sufficient indicia of intimidation is to be determined by the fact finder and assessed under the totality of the circumstances, cognizant that proof of manifest threats is not required. Insofar as Brachbill is read to mean pecuniary inducement alone will suffice without proof of intimidation, it is disapproved. While understandable, to the extent the Superior Court relied on ‘Brachbill’ to find intimidation is not needed to satisfy a conviction under 18 Pa.C.S. 4952,” the Supreme Court held the court erred. Despite clarifying Brachbill, the Court did not remand to the Superior Court to review the sufficiency of the evidence; as “the jury was properly instructed and found intimidation, additional fact finding is unnecessary.” View "Pennsylvania v. Doughty" on Justia Law

An equally divided en banc panel of the Superior Court resulted in affirmance of appellant Jacob Christine's judgment of sentence for aggravated assault, and recklessly endangering another person. Appellant was alleged to have slashed a fellow inmate's throat. Corrections officer searched appellant's cell and found a shank. Appellant filed a motion in limine to exclude the shank from evidence, arguing it was irrelevant and would cause undue prejudice by confusing the jury, because the Commonwealth agreed the shank was not used in the attack. The trial court ruled the shank admissible under multiple theories. The divided Superior Court held that the shank was properly admitted, but that the trial court erred in refusing to allow appellant to question the victim of the attack about his own conviction for simple assault. Appellant appealed admission of the shank. Finding no reversible error in the trial court's judgment, the Supreme Court affirmed. View "Pennsylvania v. Christine" on Justia Law

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