Justia Pennsylvania Supreme Court Opinion Summaries

In the Highland Garden neighborhood of the City of Chester, during the evening O'Neil Blackwood suffered a fatal gunshot wound to his head during a burglary of his home by three assailants who intended to steal cash and drugs from Victim. The assailants also assaulted his wife, while their young children were upstairs in the home. Mrs. Blackwood identified defendant Shaatan Adams as one of the assailants, although his face was covered by a clear or flesh-toned mask. Moreover, at trial, one of Defendant’s co-conspirators testified against him in exchange for a reduction of charges. A neighbor also testified to overhearing Defendant and the other assailants preparing for the crime. The Pennsylvania Supreme Court granted review to consider whether the right against self-incrimination, as protected by the United States and Pennsylvania constitutions, was implicated when a Commonwealth witness, such as an investigating detective, testified without adverse implication that the defendant refused to answer questions prior to arrest. As observed in the majority opinion in "Commonwealth v. Molina,"( __ A.3d __ (J-55-2013) (Pa. 2014) addressing the question of whether an arguably exploited reference to a defendant’s pre-arrest silence violated the defendant’s right against self-incrimination under the Pennsylvania Constitution), the Supreme Court affirmed the superior court's conclusion that defendant’s constitutional rights, in this case, were not violated by the detective’s testimony in this case. View "Pennsylvania v. Adams" on Justia Law

A jury convicted defendant Michael Molina of third degree murder and related crimes resulting from the savage beating of Melissa Snodgrass, apparently as a result of drug debts owed by Victim to Defendant. The victim told her mother, with whom she lived, that she was leaving the house to run some errands. When she did not return, the victim's mother reported her disappearance to the Missing Persons Unit of the Pittsburgh Police Department. Six months later, her decomposed remains were found under moldy clothing and other debris in the basement of a house in the Spring Garden section of Pittsburgh in which Michael Benintend, one of the prosecution’s primary witnesses, resided during the relevant time period. The issue this case presented for the Supreme Court's review centered on the Missing Persons Unit detective’s testimony and the prosecutor’s closing arguments regarding the early days of the investigation into the victim's disappearance. Following a lead that Defendant was holding the victim against her will, the Missing Persons Unit detective assigned to the case went to Defendant’s house two days after Victim’s disappearance. Pamela Deloe, another prosecution witness, answered the door and asserted that neither the victim nor Defendant were at the house. Accordingly, the detective left her card and asked that Defendant call her. Later that day, Defendant called the detective. The detective then inquired as to when Defendant had last seen the victim. He initially responded that he had not seen her for a year and a half, but then he immediately contradicted his statement, claiming instead that he had not seen her for three months. Subsequent to this contradiction, the detective testified that she asked him to come to the police station to speak to her and he refused. The Supreme Court granted review in this case to consider whether a defendant’s right against self-incrimination is violated when the prosecution utilizes a non-testifying defendant’s pre-arrest silence as substantive evidence of guilt. This was an issue of first impression, to which the United States Supreme Court had not definitively spoken. The Pennsylvania Court agreed with the Superior Court, as well as several sister courts, that the use of pre-arrest silence as substantive evidence of guilt violates a non-testifying defendant’s constitutional rights. The Pennsylvania affirmed the order of the Superior Court remanding for a new trial. However, given that the status of federal jurisprudence was uncertain, the Court based its holding in this case upon the right against self-incrimination set forth in Article I, Section 9 of the Pennsylvania Constitution. View "Pennsylvania v. Molina" on Justia Law

In 2009, following a joint investigation by the Pennsylvania Office of the Attorney General and the Centre County Drug Task Force into cocaine trafficking by appellee Gregory Palazzari, appellee was arrested and charged with multiple drug trafficking offenses under the Controlled Substances, Drug, Device and Cosmetic Act (Drug Act). The Asset Forfeiture and Money Laundering Section of the Attorney General’s Office petitioned the trial court for forfeiture of Appellee’s property located at 605 University Drive, State College pursuant to the Forfeiture Act, alleging that appellee had used the property for the storage and sale of cocaine, as well as a place to meet his drug supplier. In a discretionary appeal, the issue this case presented for the Supreme Court's review centered on the general applicability of the Pennsylvania Rules of Civil Procedure to forfeiture proceedings brought pursuant to the Forfeiture Act, specifically, the availability of summary judgment pursuant to Rule 1035.2, Pa.R.C.P. in such proceedings. Although the trial court granted forfeiture of the property to the Commonwealth upon its motion for summary judgment, the Commonwealth Court reversed, broadly holding that the Rules of Civil Procedure generally and Rule 1035.2 in particular were inapplicable to forfeiture proceedings. The Commonwealth appealed. The Supreme Court concluded that the Rules of Civil Procedure applied to forfeiture proceedings where they do not conflict with the Forfeiture Act, and that there was no conflict between the entry of summary judgment pursuant to Rule 1035.2 and the Act. As such, the Court reversed and reinstated the trial court’s entry of summary judgment in favor of the Commonwealth. View "Pennsylvania v. All That Certain Lot et al (Palazzari)" on Justia Law

Appellees Henry Daniels and Kevin Pelzer participated in a plan to kidnap and hold for ransom sixteen-year-old Alexander Porter. Appellees kidnapped the victim, bound and gagged him, and placed him in the trunk of his car. Ultimately, they determined to kill the victim. In all, the victim was held in the trunk for twenty-four hours. According to appellees' police statements and Daniels's trial testimony, appellees were unable to determine whether the youth was dead when they went to dispose of his body. Pelzer shot Porter four times in the back of the neck to remove all doubt. The jury found both appellees guilty of first-degree murder and other offenses. These cross-appeals were a continuation of their first collateral challenges to their convictions under the Post-Conviction Relief Act ("PCRA"). The Pennsylvania Supreme Court vacated the PCRA court's March 25, 2003 order, which had granted appellees a new trial. The Court reviewed three claims of trial counsel ineffectiveness, denied relief on all three claims, and remanded the case to the PCRA court for the preparation of an opinion addressing the remainder of appellees' claims. On remand, the PCRA judge retired, a new judge ordered a new penalty proceeding for each appellee, while denying guilt phase relief. The Commonwealth appealed that order, while appellees, in separate cross-appeals, sought review of additional issues upon which the PCRA court denied relief. Upon careful consideration of the record below, the Supreme Court affirmed the order of the PCRA court as it related to Kevin Pelzer, but reversed the order as it related to Henry Daniels. Thus, Pelzer was denied guilt phase relief, but the award of a new penalty phase hearing to him was affirmed, and Daniels's PCRA petition was dismissed in its entirety. View "Pennsylvania v. Daniels" on Justia Law

In an appeal by allowance, the issue before the Supreme court was whether a conviction for possession of an instrument of crime ("PIC") could be sustained when a defendant has been otherwise acquitted of related offenses involving the use of that instrument of crime, here, a firearm. Upon review of the facts of this case, the Supreme Court held that a defendant's conviction of PIC may stand under such circumstances. The Court vacated the Superior Court's order reversing Appellee James Moore's PIC conviction, and remanded to the trial court for reinstatement of Appellee's judgment of sentence. View "Pennsylvania v. Moore" on Justia Law

The Superior Court affirmed the trial court’s dismissal of this case for improper venue. A criminal complaint was filed in Monroe County charging appellant with criminal conspiracy, firearms not to be carried without a license, possession of firearm prohibited, and lending or giving of firearms prohibited. Venue was held improper based on a lack of factual connection to Monroe County. Upon review, the Supreme Court concluded this was error. The case was remanded to the trial court for further proceedings. View "Pennsylvania v. Gross" on Justia Law

In an appeal by allowance, the issue this case presented to the Pennsylvania Supreme Court was whether first-degree burglary constituted “violent behavior” pursuant to the Recidivism Risk Reduction Incentive Act (“RRRI Act”). The Court concluded that first-degree burglary is “violent behavior” as contemplated by the RRRI Act. Thus, the Court affirmed the decision of the Superior Court upholding Appellant Matthew Chester's sentence. View "Pennsylvania v. Chester" on Justia Law

Appellant Jakeem Towles and Antwain Robinson took a bus from Lancaster to Columbia to visit appellant's cousin, Tyrone Hunter, and to attend a local rap performance at a venue near Hunter's apartment. Appellant and Robinson drank alcohol and smoked marijuana over the course of the night, walking between Hunter’s apartment and the venue several times. At some point, appellant took Hunter’s handgun from his apartment and hid it in a nearby alley. At the venue, appellant interrupted Cornell Stewart and John Wright's rap performance by grabbing Wright's microphone. As a result, appellant and Wright got into a physical altercation wherein Wright hit appellant at least once. Security separated them, and escorted appellant and Robinson out the front door and Wright and Stewart out the back. Appellant immediately retrieved the handgun he hid earlier, went behind the venue, and fired three shots at Wright and Stewart. One of the shots fatally struck Stewart in the head. Appellant and Robinson fled the scene and asked a friend for a ride to Lancaster. During the trip, appellant made incriminating statements to all occupants of the vehicle, including Robinson, their friend, and two other women, and instructed them not to talk. Appellant was charged with Stewart’s homicide, the attempted homicide of Wright, and unlawful possession of a firearm (the unlawful possession charge was severed for trial). The Commonwealth filed notice of an aggravating circumstance and intent to seek the death penalty. At trial, appellant’s defense theory was to negate specific intent to kill by arguing he was in the heat of passion from the altercation with Wright and also had diminished capacity due to voluntary intoxication. The jury convicted appellant of first degree murder and attempted homicide. In the penalty phase, the jury found one aggravating circumstance: in the commission of the murder, appellant created a grave risk of death to another person in addition to Stewart. The Pennsylvania Supreme Court must affirm a death sentence unless it finds: (i) the evidence fails to support the finding of at least one aggravating circumstance; or (ii) the sentence was the product of passion, prejudice, or any other arbitrary factor. Finding no reversible error, the Court affirmed appellant's death sentence. View "Pennsylvania v. Towles" on Justia Law

Appellant Anthony Reid was convicted by jury of first-degree murder, carrying a firearm without a license, possessing an instrument of crime, and criminal conspiracy stemming from the 1988 murder of Mark Lisby. Appellant was ultimately sentenced to death for the first-degree murder conviction, 2.5 to 5 years for possession of an instrument of crime, 2.5 to 5 years for carrying a firearm without a license, and 5 to 10 years for criminal conspiracy. Appellant filed for post-conviction relief, and was denied. He appealed to the Pennsylvania Supreme Court. Finding no reversible error, the Supreme Court affirmed the PCRA court's denial of relief. View "Pennsylvania v. Reid" on Justia Law

In 1989, a group of boys was throwing snowballs at passing cars in a Philadelphia neighborhood. One of the snowballs struck a vehicle driven by Appellant Anthony Reid, who was also known as “Tone” or “Tone-Bey.” Appellant stopped his vehicle, and he and his two passengers exited the car. The boys scattered, and Appellant asked two bystanders if they were involved in throwing the snowballs. The bystanders denied involvement, and, as Appellant reached his hand inside his jacket, he replied “You better hope none was your family.” Appellant and his passengers drove around the block looking for the boys who had been throwing snowballs. When Appellant reached the stop sign, he drove the car onto the sidewalk and gunfire erupted from the passenger side of the vehicle. Michael Waters was fatally wounded. Six days later, in a separate incident, Appellant used a 10-millimeter handgun to kill Neal Wilkinson. In this incident, Appellant and a companion, Kevin Bowman, asked Wilkinson and Darryl Woods to accompany them to collect a debt. When Wilkinson and Woods ascended the stairs to the residence of the alleged debtor, Bowman shot them both with a shotgun, and Appellant then shot both men with a handgun. Woods survived and gave police a statement naming Appellant as one of the two shooters. Ten-millimeter shell casings found at the scene of the Wilkinson murder were determined to have been fired from the same gun that was used in the Waters murder six days earlier. The trial court formally imposed a death sentence on the murder conviction, and a consecutive aggregate sentence of 10-20 years imprisonment on remaining offenses. Appellant sought post-conviction relief, but was denied. Finding no reason to overturn the PCRA Court's decision, the Supreme Court affirmed. View "Pennsylvania v. Reid" on Justia Law