Justia Pennsylvania Supreme Court Opinion Summaries

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

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