Justia Pennsylvania Supreme Court Opinion Summaries

On the morning of May 27, 2016, the body of Denhad Taiedi, who owned the Jefferson Hills Motel, was discovered in the motel’s office with a fatal gunshot wound to the head. Blood stains were found on a tray inside a cash box, inside a bank bag, and on the office door, and a trail of fresh blood drops led from the motel office to the parking lot. Testing of the blood revealed that it matched Appellant Derrick Gallaway’s DNA, and, on August 26, 2016, a warrant was issued for his arrest. When officers were unable to locate Appellant at any of his known addresses, his information was entered into the National Crime Information Center (“NCIC”). More than a year later, Appellant was arrested in Carmichael, California, and he was extradited to Pennsylvania on or around December 13, 2017. On the third and final day of trial, the Commonwealth sought and was granted permission to play for the jury an edited version of Appellant’s videotaped interview by police detectives. The edited version of the videotaped interview was approximately 17 minutes long, and clearly showed Appellant in bright red prison clothing throughout. The Commonwealth asserted that the videotape evidenced Appellant’s consciousness of guilt, as it showed him making false statements to police regarding, inter alia, whether he was in Pittsburgh at the time the Victim was killed, whether he had ever stayed at the motel, and whether he knew two testifying witnesses. In this appeal by allowance, the issue this case presented for the Pennsylvania Supreme Court's consideration was whether the Superior Court’s determination that the probative value of videotape evidence which showed Appellant in prison clothing outweighed its prejudicial effect, such that admission of the evidence did not deprive Appellant of a fair trial under Estelle v. Williams, 425 U.S. 501 (1976). To this, the Court held that the probative value of the evidence was not outweighed by its prejudicial effect, and, thus, it affirmed Appellant’s judgment of sentence. View "Pennsylvania v. Gallaway" on Justia Law

Appellant Paul Taylor appealed the denial of his fifth petition for post-conviction relief. In 1991, Taylor brutally murdered his wife, two of his minor children, his mother-in-law, and his mother-in-law’s minor son. Taylor pled guilty to five counts of criminal homicide generally. Following a degree-of-guilt hearing, the trial court convicted Taylor of first-degree murder on all five counts. The matter proceeded to a penalty phase hearing, following which the trial court determined that the imposition of the death penalty was appropriate for four of Taylor’s murder convictions and that a penalty of life imprisonment was appropriate for the remaining murder conviction. The trial court formally imposed Taylor’s sentences on January 23, 1992. Petitioner premised his fourth PCRA petition upon the well-publicized scandal involving the exchange of inappropriate emails between employees of the OAG and members of the judiciary, including former Justices Eakin and McCaffery. Petitioner alleged that emails exchanged during the pendency of "Taylor IV" reflected partiality on the part of the Pennsylvania Supreme Court in disposing of his appeal, in violation of Taylor’s due process rights. The PCRA court dismissed Taylor’s fourth petition, concluding that the PCRA court lacked the authority to grant the relief that Taylor sought. Taylor then appealed. On November 6, 2019, with its participating members being equally divided on the matter, the Pennsylvania Supreme Court affirmed the PCRA court’s order by operation of law. In his fifth PCRA petition, Appellant reasserted his due process claim premised upon the alleged partiality of the Supreme Court in Taylor IV arising out of the email scandal, as well as a request for a new appeal in that matter nunc pro tunc. The Supreme Court agreed with the conclusion of the PCRA court that Appellant untimely filed his fifth petition, therefore denial was affirmed. View "Pennsylvania v. Taylor" on Justia Law

Appellant Albert Reid was convicted by jury on two counts of first-degree murder for the killings of his estranged wife, Carla Reid, and her fourteen-year-old daughter, D.M. He received two death sentences, and the Pennsylvania Supreme Court affirmed the judgment of sentence. Appellant subsequently filed a petition pursuant to the Post Conviction Relief Act (“PCRA”). The PCRA court denied the petition, and Appellant appealed to the Supreme Court, which affirmed in part the PCRA court’s order but remanded, while retaining jurisdiction, directing the PCRA court to provide a supplemental opinion addressing: why it denied relief on the whether appellant was incompetent to proceed to trial and represent himself; and whether prior counsel was ineffective for failing to investigate and effectively this issue before trial and for failing to raise it on appeal. Upon return from the PCRA court to the Supreme Court, the Supreme Court found the PCRA court erred in the manner in which it assessed Appellant’s claim that he was incompetent to stand trial, as the court’s reasoning, inter alia, failed to account for new, post-conviction evidence that potentially demonstrated that Appellant was incompetent to stand trial. Accordingly, the Court vacated in part the PCRA court’s order and remanded for further proceedings. View "Pennsylvania v. Reid" on Justia Law

The Pennsylvania Supreme Court granted discretionary review to consider whether Pennsylvania Rule of Criminal Procedure 706(C) required a trial court to consider a defendant’s ability to pay prior to imposing mandatory court costs at sentencing. In 2015, appellant Alexis Lopez entered a negotiated guilty plea to possession with intent to deliver a controlled substance. The trial court sentenced him to eleven and one-half to twenty-three months’ imprisonment, followed by three years’ probation. Six months later, the trial court granted Lopez’s motion for early release on parole. Thereafter, Lopez violated the terms of his supervision three times. Prior to resentencing for his third violation, Lopez filed a “Motion for Ability-to-Pay Hearing at Sentencing to Waive Costs.” His motion contended “Pennsylvania statutes and the Rules of Criminal Procedure require that this [c]ourt consider [his] ability to pay and waive court costs due to his indigence and the burden the costs would impose on him.” The Supreme Court found that Rule 706(C) did not have a requirement as Lopez suggested, and affirmed the Superior Court. View "Pennsylvania v. Lopez" on Justia Law

On July 5, 2014, at around 4:42 p.m., Appellee Akim Jones-Williams drove his car at approximately two miles per hour across train tracks. An approaching train collided with the car and pushed it nearly one-quarter mile before it stopped. Upon arriving at the scene, emergency personnel found Appellee outside the vehicle. Appellee’s fiance, Cori Sisti, and their daughter, S.J., were still inside the car. Medics declared Sisti dead at the scene, but transported Appellee and S.J. to York Hospital for medical treatment. Several individuals told the investigating lieutenant that they smelled burnt marijuana coming from Appellee and the car. Therefore, at approximately 6:00 p.m., the lieutenant asked a sergeant to interview Appellee at the hospital and obtain a “legal blood draw.” When the sergeant arrived at the hospital, Appellee was restrained in a hospital bed fading in and out of consciousness and unable to respond to basic questions. As such, the sergeant could not communicate to Appellee the consent of the form. Nevertheless, the sergeant later learned that hospital personnel drew Appellee’s blood at 5:56 p.m. The record did not establish why that blood was drawn, but it is clear that it was drawn prior to the sergeant's arrival. The sergeant completed paperwork requesting the hospital's lab to transfer Appellee's blood sample to a police lab for testing for controlled substances or alcohol. The resulting toxicology report revealed that Appellee’s blood contained Delta-9 THC, the active ingredient in marijuana. Appellee was arrested in April 2015, and ultimately convicted of homicide by vehicle while driving under the influence; homicide by vehicle; endangering the welfare of a child (“EWOC”); recklessly endangering another person (“REAP”); and related charges. Appellee filed an omnibus pre-trial motion, in which he moved to suppress the blood test results. He argued that police lacked probable cause that he was driving under the influence, that his blood was seized without a warrant and without satisfying the exigency exception, and that 75 Pa.C.S. § 3755 did not justify the seizure in the absence of exigent circumstances. The Pennsylvania Supreme Court concurred with the superior court that evidence from the blood sample should have been suppressed at trial. The matter was remanded for a new trial. View "Pennsylvania v. Jones-Williams" on Justia Law

Appellee Ryan Pownall, a former Philadelphia Police Officer was charged with killing David Jones by gunfire while on duty in his capacity as a police officer. Anticipating Pownall might pursue at trial a peace officer justification defense under 18 Pa.C.S. §508, the Philadelphia District Attorney’s Office (“DAO”), on behalf of the Commonwealth, filed a pretrial motion in limine seeking to preclude the trial court from using Suggested Standard Jury Instruction (Crim) §9.508B, which largely tracked Section 508. The DAO argued that since the justification statute supposedly violated the Fourth Amendment to the United States Constitution as interpreted by the Supreme Court in Tennessee v. Garner, 471 U.S. 1 (1985), so too must the standard jury instruction based on the statute. The trial court disagreed, concluding the DAO’s pretrial motion, by itself, was “insufficient to establish the unconstitutionality of Section 508[.]” Moreover, the court believed the DAO’s suggested remedy — proposing that it rewrite several disjunctive “ors” within the statute to conjunctive “ands” — was an “inappropriate” request for it to “judicially usurp the legislative function of the Pennsylvania General Assembly and rewrite Section 508 out of whole cloth.” For those reasons it denied the DAO’s request to certify the case for interlocutory appeal. When the DAO appealed anyway, the superior court quashed, reasoning the trial court’s order was not collateral and did not substantially handicap or terminate the DAO’s prosecution. The Pennsylvania Supreme Court granted review to determine whether the superior court erred in quashing the appeal. Because the Supreme Court concluded it did not, the judgment was affirmed. View "Pennsylvania v. Pownall" on Justia Law

Appellant Mark Prinkey caimed his sentence resulted from a prosecutor’s unconstitutionally vindictive decision to pursue a mandatory minimum term of years. Proceeding from the general principle that a sentence was unlawful if the sentencing court lacks the legal authority to impose that sanction, Pennyslvania law recognized four broad types of legality challenges. The issue this appeal presented for the Pennsylvania Supreme Court’s review was whether a particular type of claim constituted a challenge to the legality of the sentence, such that it was cognizable under the Post-Conviction Relief Act (PCRA): (1) a claim that a sentence was imposed pursuant to a facially unconstitutional sentencing statute; (2) an assertion that statutory preconditions to the court’s sentencing authority were not present; (3) a challenge alleging a violation or nonfulfillment of a substantive, constitutional restriction upon the court’s authority to impose the sentence; and (4) an argument that the statutory support for the conviction is void ab initio. In this case, the Court held that a challenge to a sentence as presumptively vindictive fell within the third category of legality challenges and, thus, was cognizable under the PCRA. View "Pennsylvania v. Prinkey" on Justia Law

The issue this case presented for the Pennsylvania Supreme Court’s review centered on a challenge to the lifetime registration requirement of the Revised Subchapter H of Pennsylvania’s Sex Offender Registration and Notification Act (“SORNA”), and whether that requirement was waived because Appellant Shaune Thorne, Sr. did not raise such challenges at the time of his sentencing or in a post-sentence motion but, instead, raised them for the first time in his brief to the Superior Court. After careful review, the Supreme Court concluded Appellant did not waive his Apprendi-based and cruel and unusual punishment challenges to the lifetime registration requirement set forth in Revised Subchapter H by raising them for the first time in his brief to the Superior Court, because such claims implicated the legality of a sentence and, therefore, could not be waived. Further, for purposes of clarification, the Court expressly disapproved Commonwealth v. Reslink, 257 A.3d 21 (Pa. Super. 2020) to the extent that it unnecessarily limited a sexual offender’s ability to raise constitutional challenges to Revised Subchapter H by requiring that those challenges be raised before the trial court. View "Pennsylvania v. Thorne" on Justia Law

In 2013, while in the Navy, Appellee A.L. had intercourse with the adult victim when her ability to consent was impaired by alcohol. He was charged with sexual assault under the Uniform Code of Military Justice. Appellee was tried by general court-martial, with a panel of service members acting as fact-finders. The panel returned a verdict of guilty. Appellee was sentenced to sixty days’ confinement, a reduction in rank, and a dishonorable discharge. He appealed to the United States Navy-Marine Corps Court of Criminal Appeals, which affirmed the conviction and sentence. After his discharge from the Navy, Appellee moved to Pennsylvania. He registered with the Pennsylvania State Police (“PSP”) as a sex offender subject to registration under Sexual Offender Registration and Notification Act (“SORNA”). The PSP determined Appellee’s crime triggered a Tier III registration obligation. Appellee appealed that designation, arguing PSP’s action was adjudicative and not merely ministerial. The Pennsylvania Supreme Court allowed appeal in this matter to determine whether sexual assault as defined under the Uniform Code of Military Justice was comparable to sexual assault as defined under the Pennsylvania Crimes Code so as to make Appellee a lifetime SORNA registrant. The Supreme Court concluded the military statute under which Appellee was convicted effectively defined two crimes, and PSP lacked a valid foundation to discern which of the two formed the basis for the military panel’s finding of guilt. Therefore, Appellee’s court-martial conviction could not be the basis for his classification as a Tier III registrant. View "A. L. v. PA State Police" on Justia Law

On November 17, 2017, Patrolman Brian Shaw of the City of New Kensington Police Department was shot and killed in the line of duty. At 8:06 p.m. Officer Shaw informed dispatch that a vehicle had failed to stop for his lights and sirens. Shortly afterwards, Officer Shaw announced that he was pursuing on foot. Moments later he radioed that he had been shot. Because no one witnessed the shooting, the Commonwealth established appellant Rahmel Sal Holt’s guilt through circumstantial evidence, including the testimony of Tavon Harper, the driver of the vehicle Officer Shaw attempted to stop. Holt would ultimately be convicted, for which he was sentenced to death. Appeal to the Pennsylvania Supreme Court was automatic. Finding no reversible error, the Supreme Court affirmed the sentence. View "Pennsylvania v. Holt" on Justia Law