Justia Pennsylvania Supreme Court Opinion Summaries

Eight years after the charges against him were dismissed, appellee Todd Allen petitioned to have the property seized from the vehicle he was driving at the time of his arrest returned to him. The trial court concluded appellee's claim was waived because it had not been raised before the trial court that had jurisdiction over his criminal case. The Commonwealth Court applied a six-year statute of limitations, declining to follow the authority relied upon by the trial court ("Pennsylvania v. Setzer, 392 A.2d 772 (Pa.Super 1978)), and found appellee's motion was therefore untimely. The Commonwealth appealed the Commonwealth Court's judgment, and the Supreme Court was persuaded that the Commonwealth Court erred by applying the statute of limitations analysis. The Supreme Court concluded the trial court was correct in its analysis: because appellee had a prior opportunity to move for the return of the property in the pendency of criminal charges against him, failing to do so waived the issue. View "Pennsylvania v. Allen" on Justia Law

In a discretionary appeal, the issue this case presented for the Supreme Court's review centered on whether the Superior Court erred in making certain legal determinations leading it to vacate the judgment of sentence imposed upon Appellee Tyde Pasture following the revocation of his probation. Pasture sexually molested his live-in paramour’s daughter, beginning when she was nine years of age. Upon review, the Supreme Court concluded the Superior Court misapplied certain sentencing provisions, leading it to give insufficient deference to the revocation court’s imposition of the sentence following the revocation of Pasture’s probation. The Supreme Court vacated the Superior Court’s order and reinstated Pasture’s original judgment of sentence. View "Pennsylvania v. Pasture" on Justia Law

Appellant Christopher Johnson appealed the sentence of death he received for first-degree murder and related charges in the 2010 shooting death of Officer David Grove. Grove was patrolling an area near Gettysburg National Military Park when he saw appellant's car stopped near the Battlefield. Grove was later discovered by a fellow officer, shot three times, including a fatal shot to the back of the neck. Appellant raised multiple issues on appeal to the Supreme Court, but finding no reversible error, and that the evidence sufficiently supported the sentence, the Supreme Court affirmed appellant's sentence of death. View "Pennsylvania v. Johnson" on Justia Law

In 2012, the Commonwealth filed a criminal complaint against appellee Jason Hoover alleging he and two co-conspirators, Barry Martell and D.M. (a juvenile), stole parts and equipment from RES Coal Company and later sold the stolen parts to a local salvage yard. The Commonwealth appealed Superior Court Order vacating appellee’s judgment of sentence for theft by unlawful taking, receiving stolen property, criminal conspiracy, and corruption of minors, and remanding for a new trial. The Superior Court concluded that the trial court abused its discretion in determining that the probative value of appellee’s prior crime of dishonesty substantially outweighed its prejudicial effect. The Supreme Court reversed and remanded: "[t]here was no need, or warrant, for the Superior Court to seek to innovate a novel standard for admitting a prior conviction for impeachment purposes, particularly one based on federal sources, since the applicable Pennsylvania Rule of Evidence and the corresponding federal rule, F.R.E. Rule 609, are quite distinct. Thus, while subsection (d)(2) of the corresponding federal rule limits the admissibility of juvenile adjudications to those of witnesses other than the defendant, subsection (d) of the Pennsylvania rule, as stated, contains no such limitation, but specifically allows the use of juvenile adjudications for impeachment purposes. Thus under Pennsylvania law, prior adult convictions of crimes of dishonesty remain fair game for impeachment in appropriate circumstances. The case was remanded for the Superior Court to consider appellee’s remaining claim regarding appellee’s proposed alibi testimony. View "Pennsylvania v. Hoover" on Justia Law

In 2008, a jury convicted Appellant Cletus Rivera of the first degree murder of Police Officer Scott Wertz. Appellant was sentenced to death, and the Pennsylvania Supreme Court affirmed his judgment of sentence. After affording Appellant notice of its intent to dismiss his PCRA petition without conducting an evidentiary hearing, the PCRA court dismissed Appellant’s petition, holding there were no genuine issues of material fact and no meritorious issues. Appellant appealed that decision to the Supreme Court. Finding no reversible error, the Supreme Court affirmed. View "Pennsylvania v. Rivera" on Justia Law

Appellee Andrew Enimpah was a passenger in a car stopped by police; he was asked to step out of the vehicle, and when he did, a plastic bag fell from his lap. The driver consented to a search of the car and police seized the bag, which contained cocaine. All occupants denied knowledge of the bag, but appellee was charged. He moved to suppress, challenging the constitutionality of the detention that led to the search. At the suppression hearing, the prosecutor refused to offer evidence until appellee met the "threshold" of appellee offering proof of his reasonable expectation of privacy in the area where the plastic bag was found. After much debate, the trial court informed the prosecutor it would be obliged to grant the motion if she failed to present any evidence. The prosecutor maintained her position, stating, “If I’m wrong[,] the [a]ppellate courts will tell me that[;] then I will respect that decision.” The trial court suppressed the evidence; the Superior Court affirmed. The Supreme Court affirmed that decision and reiterated that which should be clear: "In all cases, the burden of production is [] upon the Commonwealth." View "Pennsylvania v. Enimpah" on Justia Law

The issue this case presented for the Supreme Court's review centered on the constitutionality of provisions of the Sex Offender Registration and Notification Act (SORNA) as applied to juveniles. An order of the York County Court of Common Pleas held the statute unconstitutional as violative of the ex post facto clause, protections against cruel and unusual punishment, and due process rights through the use of an irrebuttable presumption. The seven juveniles in this case were previously adjudicated delinquent in regard to specific sexual crimes and were subject to juvenile court supervision on SORNA’s effective date. Accordingly, the Juveniles became subject to lifetime registration under 42 Pa.C.S. 9799.15(a)(4). The Juveniles filed motions for nunc pro tunc relief asserting SORNA’s unconstitutionality, which were consolidated by the trial court, following the passage of SORNA and its attachment to them. After review, the Supreme Court affirmed the determination that SORNA violated juvenile offenders’ due process rights through the use of an irrebuttable presumption. View "Interest of: J.B." on Justia Law

Appellant Wayne Mitchell's petition for post-conviction relief was denied, and he appealed. Appellant admitted to and was convicted of the rape of his wife Robin in 1997. He was also charged with making terroristic threats, unlawful restraint, and simple assault. While appellant waited for his preliminary hearing, the wife filed for a Protection From Abuse order. Appellant waived the charges to court in exchange for a nominal bond, with a condition that he seek immediate in-patient treatment for alcohol abuse. However, for reasons disputed at trial, Appellant was never admitted to the hospital for treatment as required by the agreement, and instead confronted his wife where he later stabbed her to death, leaving her naked body in a lot close to her home. Appellant ultimately confessed to the killing, and later pled guilty to the earlier charges against him, in addition to his wife's murder. Upon review of appellant's petition for post-conviction relief, the Supreme Court found no reversible error in the PCRA court's denial of appellant's petition for relief. View "Pennsylvania v. Mitchell" on Justia Law

In September 1992, Michael Bardo was arrested for the death and indecent assault of his three-year-old niece. Finding unanimously that the aggravating factors outweighed the mitigating factors, the jury determined that Bardo should be sentenced to death. The trial court accordingly imposed the death sentence, and in 1998, the Pennsylvania Supreme Court affirmed the judgment of sentence on direct appeal. Bardo filed a timely PCRA petition. The Court was unanimous in affirming Docket No. 650 CAP, but was evenly divided on the appeal in Docket No. 651 CAP. Therefore, the grant of penalty phase relief was affirmed by operation of law. Part II of this opinion addressed Bardo's appeal of the PCRA court's order denying him guilt-phase relief (and several other penalty-phase claims). After careful review, the Court affirmed the denial of Bardo's guilt-phase claims for relief. View "Pennsylvania v. Bardo" on Justia Law

The Commonwealth appeals from the order granting a stay of execution, vacating appellee’s death sentence, and awarding a new penalty hearing under the Post Conviction Relief Act (PCRA). Appellee was sentenced to death after being convicted of the 1986 robbery and murder of Amos Norwood. This was appellee's second murder conviction. After review of the record, the Supreme Court concluded Appellee did not prove that a timeliness exception applied to the filing of his petition for relief, and that the PCRA court erred in finding Appellee established his burden of proof under the "governmental interference" exception. The Supreme Court vacated the stay of execution and the grant of a new penalty phase, and reinstate appellee's death sentence. View "Pennsylvania v. Williams" on Justia Law