Justia Pennsylvania Supreme Court Opinion Summaries

Appellant Paul Gamboa Taylor appealed the PCRA court's dismissal of his third PCRA petition as untimely and finding trial counsel did not have a conflict of interest during his representation of appellant. Appellant, through PCRA counsel, filed a third PCRA petition alleging, for the first time, at the time he entered his guilty pleas, trial counsel had a conflict of interest which adversely affected his representation of appellant. Appellant contended trial counsel's representation of a a family member of his victim, and that representation was a conflict of interest. Specifically, appellant contended this conflict of interest caused trial counsel to abandon appellant's interests and begin working against him. The Commonwealth filed a motion to dismiss the third PCRA petition as untimely. The PCRA court ultimately determined trial counsel did not have an actual conflict of interest during his representation of appellant. Based on this determination, the PCRA court concluded there was no newly-discovered evidence of a conflict of interest that would bring appellant's petition within one of the PCRA's timeliness exceptions. Accordingly, it found the petition untimely and denied it. Upon review, the Supreme Court agreed, and concluded that the PCRA court properly found appellant failed to satisfy the newly-discovered evidence exception. His third PCRA petition was, therefore, untimely. View "Pennsylvania v. Taylor" on Justia Law

In 2007, police received information from a concerned citizen who witnessed a possible drug transaction at appellee's residence. Police investigation revealed appellee had five prior narcotics arrests, and two prior arrests and one conviction for firearms violations. A confidential informant subsequently told police he knew drugs were being sold from appellee's residence. Based on this information, police applied for and executed a search warrant for appellee's residence. After searching the inside of appellee's home, police recovered three guns, soft body armor, drug paraphernalia, and a small amount of marijuana. Appellee admitted sole possession of the contraband and was charged accordingly. Appellee moved to suppress his post-search inculpatory statements and the evidence seized from his home on the grounds the affidavit for the search warrant failed to establish probable cause. At the suppression hearing, appellee argued the affidavit did not specify where the trash was actually located when police seized it. If the trash was on the curb awaiting collection, it was abandoned, and police could lawfully search it without a warrant; if it was on appellee's porch, appellee retained a privacy interest in it, and the trash pull was unlawful. Accordingly, the trial court held the evidence obtained from the trash pulls was properly included in the affidavit, and it denied appellee's motion to suppress. Regarding appellee's challenge to the trial court's admission of testimony not contained in the affidavit, the Superior Court held the trial court violated Pa.R.Crim.P. 203(D) by considering evidence at the suppression hearing that was outside the four corners of the affidavit of probable cause. The court reasoned: [Appellee] was not challenging the trash pull itself, but rather the existence of probable cause on the face of the affidavit. Thus, the question for the trial court was whether sufficient probable cause existed within the four corners of the affidavit to support the magistrate's decision to issue the search warrant. The court concluded, the trial court was prohibited from hearing supplemental testimony on what it deemed a "second constitutional issue" and then using that evidence to determine whether there was probable cause to issue the warrant. After its review of the matter, the Supreme Court concluded that the Superior Court erred in holding the trial court violated Pa.R.Crim.P. 203(D) in the course of deciding whether a search warrant should have been issued; accordingly, the Court reversed. View "Pennsylvania v. James" on Justia Law

The Supreme Court granted allocatur to consider whether a probation condition authorizing warrantless, suspicionless searches of a probationer's home violated statutory and constitutional precepts. In 2007, a Philadelphia police officer observed appellant standing next to a parked automobile. Appellant was pointing a handgun through the passenger window at the driver. The police officer ordered appellant to drop his weapon. Appellant did not comply, but instead, gun in hand, retreated to a nearby residence. The police officer repeated his demand that appellant drop his weapon. Appellant finally complied, and placed himself on the ground in compliance with the officer's direction. The police officer, and a second officer who arrived on the scene in response to a call for back up, retrieved a loaded .38 caliber revolver. Police also recovered seven packets of marijuana and five packets of cocaine from appellant. The trial court instead sentenced appellant to a mitigated-range sentence of 2.5 to 5 years' incarceration, to be followed by three years' probation. The trial court emphasized that there was no stricter probation than Gun Court probation. As a condition of probation and of parole, the trial court authorized warrantless, suspicionless searches of appellant's residence for weapons, and prohibited him from residing in a household where anyone had a firearm. In matters that raise both constitutional and non-constitutional bases for relief, the Supreme Court attempts to resolve matters on non-constitutional grounds as practicable. In this case, the Court found under the applicable statutory construct of this case, sentencing courts were not empowered to direct that a probation officer may conduct warrantless, suspicionless searches of a probationer as a condition of probation. As such, the probation condition ordered in this case was vacated to the extent that the sentencing court found it permissible, and the case was remanded for resentencing. View "Pennsylvania v. Wilson" on Justia Law

Appellant Laquaille Bryant directly appealed his death sentence to the Supreme Court, seeking a new penalty-phased hearing on three grounds: (1) the Suppression Court erred in denying a motion to suppress; (2) the court erred in permitting "extremely inflammatory and prejudicial" photographs of the victim, introduced at the penalty phase hearing; and (3) due to prosecutorial misconduct. Finding no error, the Supreme Court affirmed Appellant's verdict and death sentence. View "Pennsylvania v. Bryant" on Justia Law

Appellant Stephen Edmiston appealed the denial of relief on two separate Post-Conviction Relief Act (PCRA) petitions: (1) the denial of relief raised in his second PCRA petition; and (2) the denial of his request for post-conviction DNA testing in support of his motion for petition. Upon review, the Supreme Court found that the claims Appellant raised regarding the second petition were untimely. Further more, the Supreme Court affirmed denial of post-conviction DNA testing because Appellant failed to demonstrate that his DNA petition was made "in a timely manner and for the purpose of demonstrating [his] actual innocence and not to delay the execution of sentence or administration of justice." View "Pennsylvania v. Edmiston" on Justia Law

Appellant Lewis Jordan, a/k/a John Lewis, pled pled guilty to murder generally in the shooting death of Philadelphia Police Officer Charles Cassidy. Following a trial by jury to determine degree of guilt, Appellant was convicted of first-degree murder and sentenced to death. In a direct appeal, Appellant raised four issues. Concluding that Appellant was not entitled to relief on any of these issues and that the evidence was sufficient to sustain Appellant's conviction, the Supreme Court affirmed the judgment of sentence. View "Pennsylvania v. Jordan" on Justia Law

In 2005, Appellees Monroe County Detective Eric Kerchner and First Assistant District Attorney Michael Mancuso were investigating and prosecuting Dennis Slayton for theft and drug-related offenses, as well as Jill Goldstein in connection with the drug offenses. Appellant John P. Karoly, Jr., Esq., was acting as Slayton's attorney. Goldstein appeared at a bail revocation hearing represented by Eric Dowdle, Esq. At the conclusion, bail was revoked and Goldstein was placed in custody at the Monroe County Correctional Facility (MCCF). The next day, Goldstein called Slayton from the jail. During the conversation, Appellant, who was with Slayton, began speaking with Goldstein. The MCCF recorded the conversation. In a direct appeal involving alleged intentional violations of the Wiretap Act, the issue before the Supreme Court was whether the Commonwealth Court erred in granting a defense motion for summary judgment. In the amended complaint, Appellant alleged that Appellees committed multiple violations of the Wiretap Act, most notably that: ADA Mancuso violated Section 5703(2) of the Act by disclosing the conversation between Appellant and Goldstein when he included it in legal filings that were not placed under seal; and ADA Mancuso and Detective Kerchner conspired to transmit such filings to the press. On the basis of this conduct, Appellant asserted that Appellees intentionally violated the statute and, as such, should be removed from their employment pursuant to Section 5726. "In [this] context, the most obvious manner of accomplishing the appropriate investigative and law-enforcement use of the intercepted conversation . . . would have been to file the motion and brief under seal. The failure to do so, as all parties acknowledge, caused the intercepted conversation to become a matter of public record." The Supreme Court found that the Commonwealth Court did not evaluate whether the unsealed filing of the motion and brief was permissible under Section 5717. Because this issue, as well as an appropriate treatment of the alleged disclosure to the press, were material to the outcome, the Court found that the Commonwealth Court improperly granted Appellees' motion for summary judgment. Thus, the case was remanded for hearings on these questions, the question of intent, and/or on whether Appellees acted in good-faith reliance on the Act. View "Karoly v. Mancuso" on Justia Law

Appellant Rasheed Simpson appealed a court of common pleas order that dismissed his petition without a hearing. In it, appellant sought relief under the Post Conviction Relief Act (PCRA) for his conviction of first degree murder, kidnapping, robbery, conspiracy and possession of an instrument of crime. Appellant was tried jointly with one of his co-conspirators, Malik Bowers. Appellant filed a pro se petition for relief under the PCRA in 2001. Counsel was appointed and filed an amended petition in 2002, and a supplemental amended petition in 2003. The Commonwealth filed a motion to dismiss in 2004. Appellant filed a reply on in 2005, and later that year, the PCRA court granted the Commonwealth's motion without a hearing, concluding Appellant's petition raised no genuine issues of material fact. Upon review, the Supreme Court affirmed the order of the PCRA court with respect to all issues, except Appellant's claim regarding trial counsel's ineffectiveness for failing to elicit testimony concerning the alleged motive and bias of a testifying witness against Appellant, as well as allegations concerning the failure to present other witnesses. The PCRA court's order in this regard was vacated, and the matter remanded back to the PCRA court for further proceedings. View "Pennsylvania v. Simpson" on Justia Law

In 2006, fourteen year old Appellant Qu'eed Batts walked up the front porch steps of a house, shot Clarence Edwards in the head, and shot Corey Hilario in the back as he attempted to flee. Mr. Edwards died on the way to the hospital while Mr. Hilario sustained serious bodily injury but eventually recovered. The issue before the Supreme Court in this case concerned the appropriate remedy for the constitutional violation that occurred when a mandatory life-without-parole sentence was imposed following appellant's first-degree murder conviction. The Superior Court considered the impact of "Miller v. Alabama" (132 S.Ct. 548 (2011)) for determination of age-appropriate sentencing, but the Supreme Court agreed with the Commonwealth's argument that the impact of "Miller" was "minimal" and that the unconstitutional portion of the sentencing scheme was the statute governing parole eligibility which did not distinguish juvenile offenders when stating that parole may not be granted to those serving a life sentence. Because this portion of the statute was severable, the Commonwealth argued that the remaining statutory sentencing provisions of the Criminal Code still required that the court impose a sentence of life imprisonment for a juvenile convicted of first-degree murder. "We find the Commonwealth's construction of the applicable statutes to be the best supported. Appellant's argument that the entire statutory sentencing scheme for first-degree murder has been rendered unconstitutional as applied to juvenile offenders is not buttressed by either the language of the relevant statutory provisions or the holding in Miller." View "Pennsylvania v. Batts" on Justia Law

The Commonwealth appealed a superior court order that quashed an interlocutory appeal of a trial court order that granted Appellee Milton Scarborough's motion for post-conviction DNA testing. Appellee's criminal convictions arose from the robbery and stabbing deaths of a mother and her two children in their home in 1976. Appellee was convicted by a jury of burglary, robbery, theft, conspiracy, and three counts of murder in the third degree. He received an aggregate sentence of 30-60 years incarceration. Appellee pursued a direct appeal, and his convictions and sentence were affirmed by the Superior Court. Appellee next pursued a petition for collateral relief under the former Post Conviction Hearing Act, which was denied by the trial court, and the denial was upheld by the Superior Court. In 2008, Appellee filed his PCRA petition raising two claims for collateral relief: a claim of "after discovered" exculpatory evidence and a "Brady" violation. With respect to the PCRA petition, the court found the petition untimely. With regard to the DNA testing, the court ordered testing of a palm print, fingernail clippings and blood evidence from the scene of the murders. The Commonwealth filed a notice of appeal from the DNA testing order, arguing that the trial court used an incorrect standard in evaluating Appellee’s request for DNA testing, namely, that the trial court considered only whether the DNA testing could be favorable to Appellee, not whether it could establish his actual innocence, which the Commonwealth contended was the proper standard. In the court's opinion, the hearing judge noted the lack of any cases in which the Commonwealth appealed an order granting DNA testing, and suggested that the DNA testing order was "perhaps" interlocutory. Even so, the Commonwealth did not request the court to amend the order to include the necessary certification for a permissive appeal from an interlocutory order, nor did the Commonwealth apply to the Superior Court for permission to appeal the order as required by Pa.R.A.P. 1311(b). Appellee filed an application in Superior Court seeking to have the Commonwealth’s appeal quashed or dismissed on the grounds that it was taken from an interlocutory order. The Commonwealth did not file a response to this application; however, it asserted in the statement of jurisdiction in its brief to the Superior Court that the order granting the DNA testing was final and appealable. The Superior Court subsequently quashed the appeal. After careful review, the Supreme Court concluded that the order granting a motion for post-conviction DNA testing in this case was a final order. Therefore the Court reversed the Superior Court's order and remanded the case for consideration of the merits of the issues presented in the Commonwealth’s appeal. View "Pennsylvania v. Scarborough" on Justia Law