Justia Pennsylvania Supreme Court Opinion Summaries

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 The Superior Court unanimously affirmed his judgment of sentence in an unpublished memorandum opinion.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

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