Justia Pennsylvania Supreme Court Opinion Summaries

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

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