Justia Pennsylvania Supreme Court Opinion Summaries

Following remand in this capital case, the Commonwealth appealed the Court of Common Pleas of Philadelphia County's order granting Appellee Richard Hackett's petition pursuant to the Post Conviction Relief Act (PCRA). After determining that Appellee proved he was "mentally retarded" and thus, exempt from execution in accordance with the United States Supreme Court's decision in "Atkins v. Virginia," (536 U.S. 304 (2002)), the PCRA court set aside Appellee's death sentence. As the PCRA court made findings which were not supported by substantial evidence of record and made an error of law by improperly equating borderline intellectual functioning with mental retardation (intellectual disability), the Supreme Court reversed the PCRA court's order vacating Appellee's death sentence and dismissed his petition for collateral relief. View "Pennsylvania v. Hackett" on Justia Law

Wes and Cynthia Collier lived in a home in Scranton, Pennsylvania with their children and step-children: 16-year-old Leslie Collier; 19-year-old Samantha Hintz; 22-year-old Dustin Hintz; and 22-year-old Matthew Collier, who was handicapped and could not walk. Appellee, then 25-years-old, moved into the Collier home. At the time, he and Samantha were boyfriend and girlfriend, and they lived in her bedroom. Between May and June 2008, Samantha and Appellee were no longer getting along, so Appellee was given his own bedroom in the basement. Appellee became angry when he found Justin Berrios, age 22, Samantha’s former boyfriend and the father of her 2-year-old child Tristan, sitting on Samantha’s bed with her. After working their shifts, Samantha gave Appellee a ride home. Appellee left for a friend’s house, and Cynthia retired for the evening at 11:00 p.m. In the early hours of July 17, 2008, Appellee returned to the Collier home and stabbed Justin to death. When police arrived at the house, they found Samantha, Cynthia and Matthew bound. Samantha had been assaulted; Justin, Leslie and Dustin were dead. Appellee was charged with three counts each of first-degree murder, second-degree murder and third-degree murder, robbery, indecent assault and kidnapping, and convicted by jury on all counts. A three-judge panel of the Superior Court, in relevant part, unanimously determined the facts were insufficient to sustain the kidnapping charge, and, as a result, the second-degree murder convictions. The Commonwealth appealed the Superior Court's judgment. Finding that the victims, although imprisoned in their home, nevertheless, were confined in a place of isolation, satisfied the Commonwealth’s definition of kidnapping. Thus, the Superior Court was reversed and the trial court's judgments of sentence reinstated. View "Pennsylvania v. Rushing" on Justia Law

A Pittsburgh police officer on foot patrol came upon Appellant Duane Jemison, Jr.'s car which was parked improperly in a legally marked handicapped parking spot. Upon running the car's license plate number, the officer discovered that the car had been carjacked a few days before. As other officers arrived at the scene, Appellant entered the car and started to drive away, but was immediately stopped by a police vehicle in his path. The officers ordered Appellant to get out of the car. Rather than complying immediately, Appellant moved one of his hands downward toward the floorboard, where one of the officers then observed a gun. After a search, officers recovered a gun with the hammer back, the safety off, and a round in the chamber from the floor of the vehicle. Appellant was charged with persons not to possess a firearm, carrying a firearm without a license, resisting arrest, and two counts of receiving stolen property. He was tried by jury for persons not to possess a firearm, after this charge had been severed from the others. To establish Appellant's guilt of this charge, the Commonwealth was required to prove that Appellant had been previously convicted of a statutorily enumerated offense that barred him from possessing a firearm, and that he had, indeed, possessed a firearm. It was undisputed that, in 2008, Appellant had been convicted of robbery, and the Commonwealth sought to introduce at trial the evidence of this robbery conviction. However, Appellant sought to stipulate only that he had been convicted of one of the enumerated offenses, without stating that the specific offense was robbery. The issue this case presented for the Supreme Court's review was the continued viability of "Commonwealth v. Stanley," (446 A.2d 583 (Pa. 1982)), where the Court held that the prosecution was not required to accept a defendant's offer to stipulate to the fact of a prior conviction when the conviction was an element of the offense charged. Concluding that "Stanley" remained good law despite the United States Supreme Court's holding in "Old Chief v. United States," (519 U.S. 172 (1997)), the Pennsylvania Court affirmed the Superior Court's order affirming Appellant's sentence. View "Pennsylvania v. Jemison Jr." on Justia Law

The Pennsylvania Turnpike Commission filed a petition for review of an order of the supervising judge of the Thirty-Third Statewide Investigating Grand Jury (Dauphin County) which denied the Commission’s motion for a protective order seeking to prohibit the Office of Attorney General from reviewing allegedly privileged or protected communications between the Commission and its counsel. Finding no reversible error, the Supreme Court affirmed the denial of the Commission's petition. View "In Re: 33rd Statewide Investigating Grand Jury" on Justia Law

The Commonwealth appealed a Superior Court order that held a trial court was required to determine whether a child victim was competent to testify prior to admitting to her out-of-court statements into evidence under the Tender Years Hearsay Act (TYHA). Upon review of the facts of this case, the Supreme Court reversed the Superior Court, holding that a determination of a child's competency under the rules of evidence is not a prerequisite to the admission of hearsay statements under TYHA. View "Pennsylvania v. Walter" on Justia Law

Appellant Imanuel Bassil Ali appealed the dismissal of his second petition for collateral relief under the Post Conviction Relief Act as untimely filed. Appellant argued he suffered from mental incompetency at relevant times during his first PCRA proceedings so as to qualify his second PCRA petition for the newly-discovered evidence exception to the PCRA time-bar. Because he failed to establish his claim by a preponderance of the evidence, the Supreme Court affirmed the dismissal. View "Pennsylvania v. Ali" on Justia Law

Appellee Christopher Williams was convicted of first degree murder and subsequently sentenced to death for the murders of three men in September of 1989. The Supreme Court affirmed the sentence on direct appeal. Appellee then sought post-conviction relief. The PCRA court initially granted Appellee relief on a basis unrelated to this appeal. The Supreme Court subsequently reversed the PCRA court and remanded for disposition of Appellee's remaining claims. On remand, the PCRA court granted Appellee a new trial, finding that trial counsel rendered ineffective assistance by failing to investigate medical and forensic evidence and finding that appellate counsel likewise rendered ineffective assistance by failing to argue on appeal that the trial court erred when it limited cross-examination of the Commonwealth's expert witnesses. Thirty days after the PCRA court entered its order granting Appellee a new trial, the Commonwealth electronically filed with the Philadelphia County Clerk of Courts a notice of appeal and jurisdictional statement appealing the grant of a new trial to the Supreme Court. The Clerk sent the Commonwealth an electronic confirmation indicating that the notice of appeal was received. Nonetheless, the Clerk refrained from time-stamping the notice of appeal on that date. Instead, the following day, the Clerk informed the Commonwealth that its notice of appeal was defective because it was missing two docket numbers and/or because the Clerk's office preferred a separate notice for each of the three docket numbers contained therein. The Commonwealth filed an amended notice of appeal that the Clerk accepted and time-stamped upon receipt. Appellee filed a Motion to Quash the Commonwealth's appeal with the Supreme Court, arguing that the appeal was untimely because the Commonwealth failed to file it within thirty days of the PCRA court's order, assuming the Commonwealth filed its notice of appeal on the date the Clerk time-stamped the amended appeal. Appellee argued the Supreme Court lacked jurisdiction to hear the appeal because of the amended filing. Finding no reversible error, the Supreme Court found the Commonwealth's appeal as timely, and denied Appellee's Motion to Quash. View "Pennsylvania v. Williams" on Justia Law

Appellee’s lengthy criminal record spans 14 pages with a total of 228 charges, terminating in four convictions, four guilty pleas, fourteen withdrawals, fifty-three dismissals, forty-four nolle prosequi, three transfers to family court, sixteen acquittals, five sustained demurrers, thirty transfers to the juvenile division, and fifty-five held for court. Between April 2010 and January 2011, Appellee filed eight separate pro se petitions in Philadelphia under the name Mark Wallace, or one of his aliases, Mark Green or James Smith, seeking destruction of fingerprints, photographs, and arrest records from past charges that had not resulted in convictions. The Commonwealth estimated that Appellee sought in total the expungement of approximately 150 charges. After determining that hearings were unnecessary, the trial court denied each of Appellee’s eight petitions in separate orders issued from May 2010 to March 2011. Appellee appealed each denial to the Superior Court, which consolidated the eight appeals and ultimately reversed the trial court in a published opinion. Having rejected the trial court’s analysis, the Superior Court concluded that “some of Appell[ee]’s non-conviction arrest records may be eligible for expungement.” However, due to confusion from the record at hand, the Superior Court was unable to determine which specific charges might be subject to expungement, and so the court remanded to the trial court for clarification. The Commonwealth filed a Petition for Allowance of Appeal to the Supreme Court on the whether the Superior Court erred by holding that an incarcerated career criminal had a due process right to a hearing at which the trial court must determine - on a charge by charge basis - whether over a hundred prior criminal charges against him should be expunged. Because the trial court’s findings "are sound and strongly supported by the record," the Supreme Court found "no reason to disturb the trial court’s holdings." The Supreme Court found that an inmate did not have the right to petition for expungment while incarcerated. Accordingly, the order of the Superior Court reversing the orders of the Court of Common Pleas of Philadelphia County was vacated and the orders of the Court of Common Pleas of Philadelphia County were reinstated. View "Pennsylvania v. Wallace" on Justia Law

In 2009, two officers on patrol in a marked police vehicle saw appellant and another male sitting on the steps of a vacant building in south Philadelphia. The officers approached the men to question their reason for loitering there, as a large number of burglaries had been reported in the area. Appellant Haleem Lyles stated his grandmother lived on the block. One officer asked for appellant’s identification, which appellant gave him. When the officer began writing down the identification information, he saw appellant place his hand in his right pocket and turn his right side away from the officer’s view; the officer told appellant to stop reaching and remove his hand. Concerned appellant might be reaching for a concealed weapon, the officer instructed him to remove his hand a second time. When appellant reached into the pocket a third time, the officer placed appellant against the wall of the building to conduct a safety frisk for weapons. Appellant once again put his hand in the pocket, so the officer forcibly removed it, and a plastic bag containing blue packets filled with crack cocaine became visible. The officer handcuffed appellant and seized the plastic bag. The officer then searched appellant and discovered a bag containing marijuana in appellant’s left pocket. Appellant was charged with possession with intent to deliver a controlled substance and possession of a controlled substance. Appellant filed a motion to suppress the drugs, which the trial court granted. The Supreme Court granted review to consider whether the Superior Court properly reversed the trial court’s suppression of evidence, which was based on a finding that an officer’s request for identification elevated an encounter to an investigative detention unsupported by reasonable suspicion. Finding no reversible error, the Supreme Court affirmed that reversal. View "Pennsylvania v. Lyles" on Justia Law

In 2011, while driving home from a funeral reception, Appellee William Bell crossed the center line of a road and struck another vehicle. A woman was killed as a result of the impact. Following trial, Bell was convicted of driving under the influence of alcohol or a controlled substance-bac.16+, homicide by vehicle while DUI, and homicide by vehicle, In this appeal, the Supreme Court addressed questions of whether convictions for homicide by vehicle and homicide by vehicle while driving under the influence (DUI) merged for operating privilege suspension purposes under the Vehicle Code, and, more generally, whether the criminal doctrine of merger was applicable to the collateral civil consequences which flow from merged, underlying criminal convictions. The Court held that the Commonwealth Court improperly found the criminal doctrine of merger was applicable in the civil arena of operating privilege suspensions under 75 Pa.C.S. sections 1532(a), (a.1). Accordingly, the Supreme Court reversed. View "Bell v. Bureau of Driver Licensing" on Justia Law