Justia Pennsylvania Supreme Court Opinion Summaries

The Commonwealth Department of Public Welfare (DPW) and the Wyoming County Human Services appealed a Commonwealth Court order reversing DPW’s Bureau of Hearings and Appeals’ order refusing to expunge an indicated report of child sexual abuse relating to a father’s alleged abuse of his four-year-old daughter. The questions before the Supreme Court in this case centered on the admissibility of a videotape of the daughter’s allegations under the relevant hearsay exception for child victims and, if admissible, whether that videotape constituted the requisite substantial evidence for denying the father’s request to expunge. Upon careful review of the record, the Supreme Court concluded that the father in this case waived any challenge to the admissibility of the videotape by failing to object before the Administrative Law Judge both when he was unrepresented on the first day of the hearing and when he was represented by counsel on the second day of the hearing. Furthermore, the Court reversed the Commonwealth Court’s determination that DPW failed to present substantial evidence to support the indicated report of sexual abuse under the Child Protective Services Law. View "R.A. v. DPW & Wyoming County Human Services" on Justia Law

This appeal stemmed from two armed robberies which occurred within two weeks of each other in October 2005 in Philadelphia. In both incidents, University students were approached by a man alleged to be Appellant, Benjamin Walker. The assailant drew a handgun, and demanded money. In this appeal by allowance the Supreme Court addressed the question of whether a trial court may, in its discretion, permit expert testimony in the area of eyewitness identification, and, in doing so, the Court reconsidered its then-current decisional law which absolutely banned such expert testimony. The Court held that, in Pennsylvania, the admission of expert testimony regarding eyewitness identification is no longer per se impermissible, and joined the majority of jurisdictions which leave the admissibility of such expert testimony to the discretion of the trial court. Thus, the order of the Superior Court was reversed, and the case remanded back to the trial court for reconsideration of such expert testimony. View "Pennsyvlania v. Walker" on Justia Law

The Commonwealth appealed a Superior Court that affirmed the pre-trial order of the court of common pleas permitting appellee Jose Alicia to introduce expert testimony concerning the phenomenon of "false confessions" at his upcoming murder trial. Appellee filed a Motion for Use of a False Confessions Expert, averring that he was of low intelligence and has been an SSI disability beneficiary due to mental health issues most of his life. The only evidence identifying Appellee as the shooter of George Rowe (other than his confession) came from two corrupt sources, one of whom initially stated that the shooter was Jeremy Duffy. Appellee believed Duffy was the shooter, and that the evidence at trial would have shown that Appellee was told by Duffy’s associates to “take the fall for the real perpetrator.” According to the Motion, the text of Appellee’s confession, along with his handwritten corrections, "provide a number of clues indicating it is a false confession." Because the Supreme Court agreed with the Commonwealth that such testimony was not admissible, the Court reversed the Superior Court and remanded this case for further proceedings. View "Pennsylvania v. Alicia" on Justia Law

Appellant Richard Baumhammers went on a two-hour crime spree in 2000 whereby he shot six racial or ethnic minorities. Four victims died of their wounds; the fifth was paralyzed from the neck down. During the spree, appellant burned his Jewish neighbor's house, and damaged two synagogues by spray painting swastikas on the outside then shooting bullets into both. Appellant was charged with five counts of first-degree murder and related offenses. He was found guilty by jury and sentenced to death. Appellant petitioned for post-conviction relief, which was ultimately denied. On appeal to the Supreme Court, appellant argued multiple instances of violations of appellant's constitutional rights were violated, and multiple instances of alleged ineffective assistance of counsel (both at trial and in the penalty phase). The Supreme Court found no reason to overturn the PCRA Court's ruling on appellant's claims of error, and therefore affirmed appellant's conviction and sentence. View "Pennsylvania v. Baumhammers" on Justia Law

Appellant fatally shot three men outside a private social club in Altoona after he and two friends were denied admission. Appellant was convicted and received the death penalty on three counts of first-degree murder. On direct appeal, appellant raised six issues for the Supreme Court's review, all challenging alleged errors in trial procedure and sufficiency of the evidence. Finding no errors, and holding that the evidence was sufficient to convict appellant and support his sentence, the Supreme Court affirmed.View "Pennsylvania v. Padilla" on Justia Law

Ronald Weiss appealed the denial of guilt-phase claims raised in his petition for post-conviction relief. Upon review, the Supreme Court concluded that the Post Conviction Relief Act (PCRA) court’s rejection of Appellant’s guilt-phase claims was supported by the record and free from legal error. However, because the PCRA court granted relief on a penalty phase issue and the Commonwealth did not cross-appeal, Appellant was afforded a new penalty hearing. Accordingly, the order of the PCRA court was affirmed. View "Pennsylvania v. Weiss" on Justia Law

The Supreme Court granted allocatur in this case to decide “whether and when a reviewing court considering a challenge to a pretrial ruling, whether in a post-verdict or appellate context, may look beyond the record of evidence presented at the suppression hearing.” The Superior Court relied on a footnote from the Court's decision in "Commonwealth v. Chacko," (459 A.2d 311 (Pa. 1983)), for the proposition that “it [was] appropriate to consider all of the testimony, not just the testimony presented at the suppression hearing, in determining whether evidence was properly admitted.” The Superior Court, (pursuant to "Chacko") considered evidence adduced for the first time at trial when deciding whether the police properly seized contraband from Appellant, L.J. Specifically, the court affirmed the trial court’s denial of suppression because trial testimony established that L.J. voluntarily consented to the search at issue. Upon review of the record, the Supreme Court found that the Superior Court’s reliance on Chacko was understandable but ultimately misplaced. Accordingly, the Court vacated the disposition order, and remanded this case to the juvenile court for a new suppression hearing. View "In the Interest of: L.J." on Justia Law

In the summer of 2005, in connection with a charity event, several persons were riding motorcycles southbound on Route 309 in Wilkes-Barre. At that same time, Appellee was driving his vehicle on Route 309 in the opposite direction. His child was in the back seat of the car. As the motorcycles approached, Appellee crossed the double yellow line and drove directly into them. One person was killed, and four others were seriously injured. A blood test to which Appellee submitted upon his arrest showed he had .76 nanograms of morphine in his system. As a result, Appellee was charged in a criminal information with multiple offenses including homicide by vehicle while driving under the influence; homicide by vehicle; aggravated assault by vehicle while driving under the influence; accidents involving death or personal injury while not properly licensed; and endangering the welfare of children. Appellee entered an open guilty plea to all 20 counts in the information. On June 9, 2006, Appellee was committed to the custody of the Department of Corrections (“DOC”) to commence serving his jail sentence. Over two years later, the trial court was asked by the DOC to comment on Appellee’s application for participation in a pre-release program. The trial court informed the DOC that Appellee was ineligible for participation in such a program “at this stage of his sentence.” The trial court further informed the DOC that a review of the transcript from Appellee’s sentencing hearing demonstrated "beyond all doubt that the intent of this court was to impose consecutive sentences.” The Commonwealth subsequently filed a Petition to Clarify Sentence, alleging that it and the DOC calculated Appellee’s aggregate term of imprisonment differently. Over Appellee’s objections, the court granted the Commonwealth's Petition and restated Appellee’s sentence. On appeal, the Superior Court held that the trial court did not have the inherent power to issue the latter order. Finding no error with the Superior Court's order, the Supreme Court affirmed. View "Pennsylvania v. Borrin" on Justia Law

Appellee was sentenced to death for the 1998 murder of James Mowery. Although represented, Appellee filed a pro se document in federal court, demanding that his direct appeal be discontinued and that he be allowed to proceed immediately to execution. Appellee also filed papers reflecting that he wished to discharge counsel due to irreconcilable differences, and that counsel was forbidden to communicate with Appellee. Shortly thereafter, in December 2008, the Supreme Court affirmed Appellee’s judgment of sentence. Appellee asked the federal district court to supply him with a replacement attorney to assist him in pursuing guilt-phase claims at federal court. The court denied the request, stating that Appellee had not established the existence of an irreconcilable conflict with counsel. Separately, Appellee petitioned the Third Circuit Court of Appeals for mandamus relief in the form of an order directing the district court to rule on his pro se filings. In August 2010, the Third Circuit denied the petition without prejudice, retaining jurisdiction and instructing the district court to determine whether Appellee was competent to waive counsel. The Commonwealth appealed an order finding Appellee incompetent to waive his state post-conviction rights, including his right to counsel. The Supreme Court determined the Commonwealth was not entitled to relief, and ultimately affirmed the PCRA court's order. View "Pennsylvania v. Wright" on Justia Law

Appellant Christopher Roney appealed the denial of his petition filed pursuant to the Post Conviction Relief Act (“PCRA”), following his conviction of first-degree murder and other offenses, the imposition of a sentence of death, and the Supreme Court's affirmance of his judgment of sentence. Finding that the PCRA court's determinations were supported by the record and free of legal error, the Supreme Court affirmed the PCRA court's order. View "Pennsylvania v. Roney" on Justia Law