Justia Pennsylvania Supreme Court Opinion Summaries

Appellant Patrick Stollar was convicted for the murder of an elderly Upper Saint Clair woman in 2003. Appellant received the death penalty for the murder, as well as a ten to twenty year sentence for predicate robbery and burglary charges. Appellant appealed the denial of his post-sentence motions, raising three issues for the Supreme Court's consideration. After review of those issues, the Supreme Court concluded the arguments appellant raised were without merit and affirmed his convictions and sentences.View "Pennsylvania v. Stollar" on Justia Law

Appellant Kenneth Hairston was convicted of two counts of murder and sentenced to death for each count. He failed to file a timely post-conviction motion or appeal, and thereby waived any claims of error. The Supreme Court automatically reviewed the case, evaluated the sufficiency of the evidence supporting the convictions, and the sentences appellants receive. The Supreme Court affirmed appellant's convictions and sentence. Appellant thereafter moved for reinstatement of his appellate rights nunc pro tunc. After the trial court granted appellant's motion, he raised numerous claims of error at trial relating to his convictions. Upon consideration of those claims, the Supreme Court found no reversible error and reaffirmed his convictions and death sentence. View "Pennsylvania v. Hairston" on Justia Law

In an interlocutory appeal, appellant Gordon Williams appealed the Superior Court's order reversing the trial court's determination that he had the right to present testimony of an expert witness to rebut the Commonwealth's evidence in support of its motion to allow a child victim to testify at a preliminary hearing via contemporaneous alternative method. Finding no reversible error, the Supreme Court affirmed.View "Pennsylvania v. Williams" on Justia Law

The Commonwealth appealed a Superior Court order which reversed an order denying Appellee’s petition pursuant to the Post Conviction Relief Act (PCRA), vacated his judgment of sentence, and remanded for a new trial. Appellee, who was on parole for a robbery conviction at the time, and his brother, Dustin Spotz, got into an argument. The argument began when Dustin’s fiancee's teenage son placed a pet gerbil in front of Appellee’s face while he was watching television, resulting in Appellee yelling at the child and threatening to physically harm him. This angered Dustin, and the argument escalated into a physical confrontation, during which Dustin stabbed Appellee twice in the upper back with a butter knife, slightly wounding him. In response, Appellee threatened to kill Dustin, and he proceeded upstairs, returning with a handgun. Appellee fired eight shots at Dustin, two of which fatally struck Dustin in the chest. Appellee was charged with first degree murder, third degree murder, voluntary manslaughter, aggravated assault, recklessly endangering another person, carrying a firearm without a license, and former convict not to own a firearm. Appellee took the stand at trial, claiming self-defense and defense of others, seeking an outright acquittal of the non-firearms charges. The jury acquitted Appellee of first and third degree murder, but convicted him of voluntary manslaughter (heat of passion), aggravated assault, recklessly endangering another person, and the firearms offenses. No timely direct appeal followed. However, in early 1996, Appellee filed a timely petition for PCRA relief in which he claimed ineffective assistance of trial counsel for failing to file a timely appeal from his judgment of sentence and seeking the restoration of his direct appeal rights nunc pro tunc. Following a hearing, the PCRA court granted Appellee relief, and he later filed a timely nunc pro tunc appeal. The Commonwealth subsequently filed a petition for allowance of appeal challenging the Superior Court’s summary finding trial counsel was ineffective. Appellee filed a protective cross-petition alleging the Superior Court erred in failing to address and resolve his additional ineffective assistance of counsel claims. Upon review, the Supreme Court concluded the Superior Court erred in vacating Appellee’s judgment of sentence and awarding him a new trial due to trial counsel’s ineffectiveness.View "Pennsylvania v. Spotz" on Justia Law

Appellant Francis Lagenella, Jr. argued on appeal to the Supreme Court that the Superior Court erred in affirming the trial court's denial of his motion to suppress evidence seized by a police officer during a warrantless inventory search of his vehicle following a valid traffic stop. Upon careful consideration of the trial court record, the Supreme Court concluded there was no basis for the officer to conduct an inventory search of Appellant's vehicle, therefore that the evidence discovered during the inventory search should have been suppressed.View "Pennsylvania v. Lagenella Jr." on Justia Law

Appellant Guillermo Ramos entered an open guilty plea to charges of Manufacturing of a Controlled Substance (Marijuana) and Possession with Intent to Deliver a Controlled Substance (Marijuana) (PWID) both of which were violations of 35 P.S. 780-113(a)(30). The Commonwealth provided written notice that it intended to proceed under the mandatory sentencing provision of 42 Pa.C.S. 9712.1 and 35 Pa.C.S. 780-113(a)(30) with regard to Ramos’s guilty plea to the PWID count. The trial court sentenced Ramos to an aggregate sentence of five months to ten years in prison. Specifically, Ramos received nine months to five years in prison on the Manufacturing of a Controlled Substance (Marijuana) conviction to run concurrently with a term of five months to ten years in prison on the PWID conviction. In an amended sentencing order after stating its belief that the sentence it had imposed on the PWID count exceeded the allowable statutory maximum, the sentencing court modified the sentence for that conviction to a flat, five year prison term which it deemed to be a mandatory sentence pursuant to 42 Pa.C.S. 9712.1. The Superior Court unanimously affirmed his judgment of sentence in an unpublished memorandum opinion. Ramos challenged on appeal to the Supreme Court the legality of imposing a mandatory minimum sentence pursuant to 42 Pa.C.S. 9712.1. After review, the Supreme Court concluded that as the most recent and the specific statute, 42 Pa.C.S. 9712.1 controlled in this case. Accordingly, under 1 Pa.C.S. 1933, the general provision of 42 Pa.C.S. 9756(b)(1) must yield to the specific sentencing provisions of Section 9712.1(a) and Section 780-113(f)(2), respectively requiring a five-year mandatory minimum sentence and a maximum sentence of no more than five years for a violation of Section 780-113(a)(30). As such, the trial court properly imposed a flat, five-year prison sentence for Ramos’s PWID conviction. View "Pennsylvania v. Ramos" on Justia Law

The issue on appeal before the Supreme Court in this matter involved questions of statutory construction pertaining to the five-year mandatory minimum sentence attaching to the offense of possession of a controlled substance with intent to deliver while in possession or control of a firearm. Specifically, the Supreme Court considered the meaning of the terms "control of a firearm" and "close proximity," as used in Section 9712.1(a), including the interrelationship between "control" and the concept of constructive possession as it appears in several Superior Court decisions. Appellant was charged with PWID, simple possession, possession of drug paraphernalia, and possession of an instrument of crime (the handgun). At a pre-trial conference, Appellant argued that the charge of possession of an instrument of crime should have been quashed, "given [the] lack of nexus between [Appellant] and that weapon and someone else's room." A common pleas judge quashed the charge, without explaining the reasoning underlying such ruling. The Supreme Court remanded the case for resentencing, with the admonition that imposition of the mandatory sentence under Section 9712.1(a) was not foreclosed. Should the lower court determine that the Commonwealth did not establish by a preponderance that Appellant was in constructive control of the firearm, the court should implement individualized sentencing, "per the usual practices." View "Pennsylvania v. Hanson" on Justia Law

Appellant Robert Diamond received two death sentences after pleading guilty to the first degree murders of Angel Guadalupe and Reginald Woodson. Appellant claimed on appeal that the trial court erred in the penalty phase, erred in finding statutory aggravating circumstances, erred in failing to find mitigating circumstances, erred in its weighing of aggravating and mitigating circumstances, and that his sentence was based on arbitrary factors. Finding no merit to appellant's challenges, the Supreme Court affirmed his conviction and judgment of sentence. View "Pennsylvania v. Diamond" on Justia Law

Appellant Harold Murray, IV, appealed the death sentence he received for his conviction on three counts of first degree murder. Upon review of the facts of this case, the Supreme Court affirmed the convictions, but vacated the death sentence. The case was remanded for a new penalty hearing. View "Pennsylvania v. Murray IV" on Justia Law

Appellant raped and brutally murdered three women in separate incidents over a one-year span. Prior to the capital murder trial, appellant pled guilty to three counts of burglary, two counts of attempted criminal homicide, and two counts of firearms not to be carried without a license. The jury returned a guilty verdict of first-degree murder for each murder as well as guilty verdicts on all remaining charges. Appellant appealed a Court of Common Pleas order his first petition for relief. Finding that appellant did not meet his burden for relief, the Supreme Court affirmed the PCRA court. View "Pennsylvania v. Robinson" on Justia Law