Justia Pennsylvania Supreme Court Opinion Summaries

Appellant was convicted on two counts of first-degree murder for the shooting deaths of Mendez Thomas and Lisa Diaz. On appeal, appellant challenged the sufficiency of the evidence presented against him at trial. After review of the trial court record, the Supreme Court found the evidence sufficient to support appellant's murder convictions. View "Pennsylvania v. Sanchez" on Justia Law

Appellant Alexander Keaton appealed the denial of his petition for post-conviction relief. He claimed the PCRA court erroneously denied the underlying claim that his invoking a Fifth Amendment right to counsel during custodial interrogations on a rape charge invalidated his uncounseled, incriminating statements given weeks later in an unrelated murder and rape case. Upon review of the matter, the Supreme Court found appellant never invoked his right to counsel in the initial rape case, and as such, the PCRA court did not err in denying appellant relief.View "Pennsylvania v. Keaton" on Justia Law

Appellee was arrested and charged with knowing and intentional possession of a controlled substance, possession with intent to deliver a controlled substance (PWID), and conspiracy with another to commit PWID. At appellee’s bench trial, the Commonwealth presented Officer Richard Cujdik’s testimony, money seized from the other person, and the drugs. The trial court found appellee guilty of conspiracy and possession of a controlled substance, but not guilty of PWID. Appellee was then sentenced to six to 23 months imprisonment followed by two years' probation for conspiracy, and a concurrent six to 23 months imprisonment and one year of probation for possession. Four days after the trial, the Philadelphia Daily News published an article alleging police misconduct by Officer Cujdik, his brother (also a narcotics officer), and other officers during a raid of a convenience store in 2007. In this appeal, the issue on appeal to the Supreme Court was whether a newspaper article submitted as the sole support for a motion for new trial on the basis of after-discovered evidence warranted the grant of a hearing. Finding allegations in an article did not constitute evidence, the Supreme Court reversed the Superior Court’s order remanding for a hearing on appellee’s after-discovered evidence claim. View "Pennsylvania v. Castro" on Justia Law

Appellant raised twenty-five lettered issues, "nearly exhausting the alphabet," to challenge the two death sentences he received after a jury convicted him of first degree murder and abuse of corpse. "Appellant’s brief is replete with beyond-boilerplate allegations containing sparse argument and even less citation to supporting authority or identification of pertinent portions of the record. His attempt to incorporate the entire trial transcript into his brief [was] insufficient, [. . .] as are his bald assertions containing no developed argument." Finding no reversible error, the Supreme Court affirmed appellant's convictions and sentences. View "Pennsylvania v. Perez" on Justia Law

The Commonwealth filed a criminal complaint charging appellee Junius Burno with, inter alia, two counts of criminal homicide. A jury found him guilty on two counts of first-degree murder. The jury found one aggravating circumstance and the mitigation catchall, and determined that the aggravating circumstance outweighed the mitigating, thus sentencing appellee to death. The Commonwealth appealed the trial court’s order granting appellee a new trial based on his trial counsel’s alleged ineffective representation in failing to object to remarks made by the prosecutor during her closing argument to the jury. Appellee filed a cross-appeal claiming the trial court erred in refusing to grant him relief on numerous remaining issues, which he raised in post-sentence motions. Upon review of the trial court record, the Supreme Court reversed the trial court’s order granting Burno’s motion for a new trial, remanded for the resolution of any pending preserved claims related to trial court error raised in appellee's post-sentence motion, and dismissed his claims of ineffective assistance of trial counsel without prejudice to his right to pursue those collateral claims under the PCRA. View "Pennsylvania v. Burno" on Justia Law

The issue before the Supreme Court in this case centered on the proper scope of the “illegal sentence” doctrine. The Superior Court held that the claim at the heart of this appeal, implicated the legality of appellee’s sentence; found that the claim was meritorious; vacated appellee’s aggravated assault conviction; and then directed that the principle of double jeopardy precluded appellee from being recharged in connection with the assault. The Supreme Court addressed the question of whether the claim was subject to waiver. The Court found that appellee’s claim concerning her underlying conviction for aggravated assault did not implicate the legality of the sentence for purposes of issue preservation. Accordingly, the Court vacated the Superior Court's order and remanded the case back to to that court for consideration of appellee’s remaining appellate claims. View "Pennsylvania v. Spruill" on Justia Law

The Commonwealth appealed a court of common pleas order that declared Section 9543(a)(1)(i) of the Post-Conviction Relief Act (PCRA) was unconstitutional as applied to Petitioner Emma Turner. The PCRA court held that barring Petitioner from obtaining collateral relief on her timely claim of trial counsel ineffectiveness because she had completed serving her sentence, as Section 9543(a)(1)(i) requires, would violate Petitioner’s constitutional due process right to be heard on this issue. The PCRA court, therefore, permitted Petitioner to proceed with her PCRA petition, despite her ineligibility under Section 9543(a)(1)(i), granted an evidentiary hearing, and ultimately awarded her a new trial. Because the Supreme Court concluded that Petitioner had no due process right to be heard outside of the limits imposed by Section 9543(a)(1)(i) of the PCRA, and that she had the opportunity to attempt to vindicate her claim on direct appeal under "Commonwealth v. Bomar," (826 A.2d 831 (Pa. 2003)), or within the time frame permitted by the PCRA, the Court reversed the PCRA court's decision and held that this section was constitutional as applied to Petitioner.View "Pennsylvania v. Turner" on Justia Law

In 1994, Appellee Joseph Elliott was convicted of the first degree murder of Kimberly Griffith, and sentenced to death. Following the denial of relief on direct appeal, appellee filed a petition for collateral relief. Without holding an evidentiary hearing, the Court of Common Pleas of Philadelphia County (the PCRA court) granted appellee a new trial on the following grounds: (1) that trial counsel was ineffective for failing to prepare for trial or interview appellee in person prior to trial; and (2) that trial counsel was ineffective for failing to object to the medical examiner’s testimony regarding the estimated time of the victim’s death. The PCRA court denied appellant relief on his remaining claims. The Commonwealth appealed the PCRA court’s grant of a new trial, and appellee filed a cross-appeal from the denial of relief on his other issues. After careful consideration of the PCRA Court record, the Supreme Court found appellee did not meet his burden to prove he received ineffective assistance of counsel, and that it was an error for the lower court to grant a new trial without an evidentiary hearing. Therefore the Supreme Court reversed the grant of a new trial, and affirmed the denial of relief on appellee's remaining claims.View "Pennsylvania v. Elliott" on Justia Law

Appellant Kevin Mattison directly appealed his death sentence to the Supreme Court. He was convicted for first-degree murder for his involvement in the 2008 death of Christian Agosto. After careful consideration of the issues Appellant raised on appeal, the Supreme Court concluded all of the issues raised lacked merit. Therefore, the Court affirmed Appellant's death sentence. View "Pennsylvania v. Mattison" on Justia Law

Appellant Michael Ballard directly appealed his death sentence to the Pennsylvania Supreme Court. He pled guilty to four counts of first-degree murder. On appeal, Appellant raised four claims of trial court error regarding aspects of the penalty-phase hearing, the admissibility of victim-impact testimony, and the jury's weighing of statutory aggravating and mitigating circumstances. Finding no reversible error, the Supreme Court affirmed Appellant's sentence. View "Pennsylvania v. Ballard" on Justia Law