Justia Pennsylvania Supreme Court Opinion Summaries

Appellant Harold Winston Noel, Jr., was convicted of robbery and related offenses, and sentenced to an aggregate 29 to 58 years’ imprisonment for these crimes. In this discretionary appeal, he did not challenge the sufficiency of the evidence to sustain his convictions, but instead insisted that the trial court’s failure to conduct voir dire in strict compliance with Rule 631 of the Pennsylvania Rules of Criminal Procedure entitled him to a new trial. After careful consideration of appellant's argument on appeal and the prejudice it was alleged to have caused, the Supreme Court found no reversible error in the jury selection process employed by the trial court. View "Pennsylvania v. Noel" on Justia Law

The issue this Post Conviction Relief Act (“PCRA”) appeal presented for the Pennsylvania Supreme Court's review centered on a claim of ineffective assistance of counsel relative to counsel’s failure to seek suppression of an inculpatory post-polygraph statement made subsequent to a pre-polygraph counseled waiver defendant's Miranda rights. The PCRA court below denied relief. A divided Superior Court reversed and remanded in a 2-1 decision, in the process adopting and applying a test for measuring Miranda waivers devised by the U.S. Circuit Court of Appeals for the First Circuit after the trial in this matter. The panel majority held that: (1) appellee’s prepolygraph Miranda waiver did not encompass the post-polygraph interview; (2) the Commonwealth failed to prove that appellee validly waived his Sixth Amendment right to counsel for the post-polygraph interview; (3) appellee’s trial counsel lacked a reasonable basis for failing to seek suppression of the statement; and (4) the admission of the statement at trial was prejudicial. The Supreme Court granted certiorari because the Superior Court’s approach led to an underlying merits holding that presented an important issue of first impression. After review of this case, the Court held that the Superior Court’s approach was flawed in multiple respects, requiring a remand to that court to reconsider the ineffectiveness claim under the proper review paradigm. Accordingly, the Court vacated the order of the Superior Court and remanded for reconsideration of the issue. View "Pennsylvania v. Hill" on Justia Law

In 2003, appellant Fred Moran was an elected member of the Board of Commissioners of Haverford Township, Delaware County. The board decided to sell a 209-acre parcel of land on which the former Haverford State Mental Hospital was located. On December 19, 2005, the board held a special public meeting to address a looming revenue shortfall for the upcoming year. During the meeting, as Commissioner Andrew Lewis recalled in his trial testimony, appellant proposed accelerating the collection of real estate taxes as a way to raise revenue; particularly, he suggested having a consultant purchasing the a portion of the parcel, Goldenberg-Pohlig (GP) pre-pay $500,000 of the 2006 realty taxes on the parcel. The next day, Lewis and appellant had a phone conversation with Michael Lawry, a principal with GP. Lewis informed Lawry the board was addressing a budgetary shortfall and told him appellant had a proposal. Appellant then said to Lawry, “[C]all it extortion, call it what you will. We need $500,000, and we’ll accelerate the zoning. We’ll get you the zoning approvals you need and accelerate the process.” Lewis recalled Lawry asked whether the $500,000 was included in the $17.5 million, and appellant indicated it would be added to the purchase price. Lawry responded he was not in a position to answer but would discuss the matter with others at GP and get back in touch with appellant and Lewis. A few minutes later, Lewis called Lawry back and told him, “I want no part of that conversation. Haverford Township is not in the business of selling zoning.” Lewis testified he called appellant the next day and essentially told him the same thing. Appellant was charged with and later convicted for bribery in official and political matters. On appeal of that conviction, he challenged the sufficiency of the evidence presented against him, and also raised the question of whether bribery (as charged) was a strict liability crime. The Supreme Court concluded after review that bribery in official and political matters was not a strict liability crime, and that there was sufficient evidence to support appellant's conviction. View "Pennsylvania v. Moran" on Justia Law

The Commonwealth appealed the reversal of appellee Willie Brooks' sentence and grant of a new trial. Appellee was appointed defense counsel after being charged with criminal attempt to commit homicide, possession of a firearm, possession of an instrument of crime, and loitering and prowling at night. After a pre-trial conference was continued six times, trial was set nearly two and a half years after appellee was originally charged. The day jury selection was to begin, appellee asked for leave to represent himself, and asked for a continuance to prepare his defense. The trial court surmised that appellee's latest request was a delaying tactic and denied the continuance. The Superior Court reversed the trial court's decision, ruling that it was error to deny appellee's last continuance request. The Commonwealth appealed the Superior Court's decision. The Supreme Court concluded the trial court did not abuse its discretion under the circumstances of this case, vacated the Superior Court's reversal, and reinstated appellee's conviction and sentence. View "Pennsylvania v. Brooks" on Justia Law

Appellant Terry Taylor was sentenced for driving under the influence of alcohol or a controlled substance (DUI), without a “full assessment for alcohol and drug addiction,” which is required “prior to sentencing” by Section 3814(2) of the Vehicle Code, 75 Pa.C.S. sec. 3814(2). His sentence was imposed without consideration of the drug or alcohol treatment recommendations that an Assessment may have provided. Appellant, argued that he was entitled to have his sentence vacated, to be assessed in compliance with Section 3814(2), and to be resentenced after consideration of any treatment recommendations. The Superior Court rejected this argument, and upheld his judgment of sentence. Because the Supreme Court agreed with Appellant that the presentence requirement of Section 3814(2) was a mandatory component of the sentencing scheme for DUI offenders, and that a sentence imposed contrary to these requirements cannot stand, the Court reversed and remanded for resentencing after compliance with Sections 3804, 3814, and 3815 of the Vehicle Code. View "Pennsylvania v. Taylor" on Justia Law

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