Justia Pennsylvania Supreme Court Opinion Summaries

In this capital post-conviction matter, Carolyn Ann King appealed an order denying guilt-phase relief but granting a new sentencing hearing. In 1993, Appellant's co-defendant Bradley Martin received a prison visitation pass that allowed him to leave the Lebanon County prison where he was incarcerated. He met Appellant, with whom he was romantically involved, and failed to return to prison as required. Instead, the two traveled to Palmyra, where they visited Guy Goodman, with whom Martin was acquainted. After arriving at Goodman's home, Martin struck Goodman over the head with a vase, and the pair disabled Goodman by tightly binding his wrists, ankles, and neck. They then placed various wrappings around his head, sealing them with duct tape. Finally, they carried Goodman into the basement, tying him even more securely and wrapping him in a bedspread, and then leaving him to suffocate while they stole his checkbook and credit card and fled in his car. During their flight, Appellant and Martin used Goodman's credit card and checks to pay their expenses. Martin and Appellant were eventually apprehended in Arizona. In 2000, Appellant filed a timely, pro se petition under the Post Conviction Relief Act (PCRA). Thereafter, she was given permission to file a counseled, amended petition, and her execution was stayed pending final resolution of her claims. New counsel for Appellant filed amended and supplemental petitions, raising numerous claims for collateral relief predicated on trial counsel's alleged ineffectiveness. The PCRA court ultimately denied Appellant's request for a new trial, finding all her guilt-phase claims meritless. It did grant Appellant a new penalty hearing based on its determination that her trial counsel had rendered ineffective assistance by failing to investigate and present any mental-health mitigating evidence. Upon review, the Supreme Court concluded that because none of the issues Appellant raised on appeal entitled her to a new trial, the order of the Court of Common Pleas was affirmed. View "Pennsylvania v. King" on Justia Law

The question presented to the Supreme Court in this case was whether a criminal defendant’s right to be present in the courtroom at every critical stage of his or her trial, including during the impaneling of a jury, categorically mandates the defendant’s personal ability to hear each venireperson who is questioned at sidebar during voir dire proceedings conducted by the court, his counsel, and the prosecuting attorney as to substantive issues. The Supreme Court concluded that it did not based upon the principle that a defendant’s right to be present in the courtroom at every stage of his or her trial is not absolute, and that under certain circumstances, including where the defendant is physically present in the courtroom and is represented by counsel, the right to be present at every stage of trial is vindicated without the defendant’s being personally able to hear the questioning of each venireperson at sidebar. Because Appellant Christian Hunsberger was physically present in the courtroom during sidebar voir dire proceedings, was represented by counsel, and interacted with counsel during these proceedings, his claim that counsel was ineffective for failing to advise him that he had a right to be present at sidebar was "without arguable merit." Accordingly, the Court affirmed the order of the Superior Court denying relief. View "Pennsylvania v. Hunsberger" on Justia Law

Appellant Donte Thomas directly appealed his death sentence for first degree murder to the Supreme Court. On appeal, he argued prosecutorial misconduct, errors at trial and ineffective assistance of counsel as grounds for reversal. Following a review of the facts and trial court record, the Supreme Court concluded there was no misconduct, no errors by the trial court, and that Appellant received effective assistance of counsel. Accordingly, the Court affirmed Appellant's sentence. View "Pennsylvania v. Thomas" on Justia Law

Following several evidentiary hearings in this post-conviction capital case, the Court of Common Pleas of Berks County (PCRA court) dismissed the petition filed by Appellant Jose Busanet pursuant to the Post Conviction Relief Act. Appellant filed his PCRA petition on September 24, 2004, and amended it on December 14, 2004. Upon Appellant’s motion, the PCRA court judge, who had presided over Appellant’s trial, recused himself from the PCRA proceeding based on general comments the judge had made in an unrelated case, which referenced his frustration with cases involving drug dealing and gun violence in the City of Reading. A new PCRA court judge was assigned to the case. During the next few years, several different counsel withdrew their appearance due to conflicts of interest. Appellant filed amendments to his PCRA petition on September 14, 2007, and January 7, 2009. On February 7, 2011, the PCRA court entered an Order and Opinion, examining thoroughly each of Appellant’s several claims, and denying PCRA relief. In his direct appeal from the denial of PCRA relief, Appellant raised thirteen issues. Upon careful consideration of each of Appellant's issues raised on appeal, the Supreme Court found no error, and affirmed the PCRA Court's dismissal the PCRA petition. View "Pennsylvania v. Busanet" on Justia Law

Appellant Aaron Jones' third petition for PCRA relief was denied as untimely, and he appealed to the Supreme Court. Appellant was convicted of first degree murder and sentenced to death for ordering the murder of a rival gang member. After multiple unsuccessful attempts to get PCRA relief, Appellant filed an unsuccessful petition for the writ of habeas corpus. When that too was denied, Appellant filed a third PCRA petition, alleging that he received newly-discovered evidence and that his untimely petition should be excepted from the PCRA's timeliness requirement. Upon review, the Supreme Court found no merit to Appellant's arguments, and ruled that his petition was clearly untimely and properly dismissed by the PCRA court. View "Pennsylvania v. Jones" on Justia Law

The Supreme Court granted review of this case to address the applicability of Section 9543(b) of the Post Conviction Relief Act (PCRA) to delays in filing amended post-conviction petitions, and the related issue of what obligation (if any) a petitioner had to move the litigation of his petition forward. In 1988, Petitioner filed a pro se application for post-conviction relief. A public defender was appointed to serve as his counsel upon remand to the PCRA court, but no further docket entries appeared in Petitioner's case until 2003 when Petitioner acting pro se filed a document seeking "extension of post-conviction relief petition." The extension was treated as an untimely and successive PCRA petition. On remand, the case was again assigned counsel, and that counsel filed an amended PCRA petition, raising numerous claims regarding Petitioner's trial counsel's ineffective assistance. The PCRA court issued an opinion dismissing the matter with prejudice. The court cited that too much time as passed to be able to mount a defense as fifteen witnesses were no longer available: "the absence of witnesses as well as the likelihood that memories would be poor twenty-four years after trial… would severely prejudice the Commonwealth's ability to retry" Petitioner. Accordingly, the PCRA court dismissed the matter; the Superior Court affirmed. Upon review the Supreme Court affirmed, concluding that the Legislature balanced policy concerns implicated by protracted litigation of PCRA claims and determined that in certain instances of substantial delay, the prejudice suffered by the Commonwealth as a result of that delay, as demonstrated at an evidentiary hearing, justifies dismissal of an original or amended petition. View "Pennsylvania v. Renchenski" on Justia Law

In this appeal by allowance, the issue before the Supreme Court was whether the Superior Court improperly reversed a revocation of probation, when the revocation was premised upon the conclusion that a probationer violated restrictions contained within a document entitled "Standard Special Conditions for Sex Offenders," which was authored by the Pennsylvania Board of Probation and Parole (the Board), rather than a judge of the court of common pleas. Upon review, the Court held that the Superior Court erred in reversing the revocation of probation. The Superior Court's order was vacated and the case remanded for further proceedings. View "Pennsylvania v. Elliott" on Justia Law

This appeal by the Commonwealth, the prevailing party at trial which was aggrieved by the Superior Court's grant of a new trial, centered on principles of self-defense for purposes of assessing whether the trial court abused its discretion in excluding evidence of the murder victim's nine-year-old conviction for robbery. The Commonwealth contended, among other points, that the Superior Court's assessment of the evidentiary ruling misapprehended the law governing self-defense. Upon review of the trial court record and the briefs submitted on appeal, the Supreme Court agreed with the Commonwealth and reversed the Superior Court, reinstating the judgment of sentence for first-degree murder, aggravated assault and related offenses in the underlying case. View "Pennsylvania v. Mouzon" on Justia Law

In this appeal, the Supreme Court was presented with two questions: (1) whether a defendant's convictions for first-degree murder and other crimes which rest solely on subsequently recanted out-of-court statements given to police violates the due process guarantees of either the United States or Pennsylvania Constitutions; and (2) whether the confessions of a former co-defendant should have been admitted as evidence as statements against interest under Pa.R.E. 804(b)(3). After careful consideration, the Court held that the recanting witnesses' out-of-court statements to the police were sufficient to sustain Appellant's convictions against a due process challenge. However, because the Court also found that the trial court erred by not allowing other portions of the co-defendant's confessions to be entered into evidence as statements against interest, the Court was "constrained" to vacate Appellant's convictions and remand the case for a new trial. View "Pennsylvania v. Brown" on Justia Law

Appellant Bortela Philistin appealed an order that denied him relief from his criminal convictions and death sentence pursuant to the Post Conviction Relief Act. A jury convicted Appellant of first degree murder and related offenses. In the penalty phase, the jury found the existence of two aggravating circumstances: the victim was a police officer killed in the performance of his duties, and the Appellant knowingly created a grave risk of death to another. The jury found no mitigating circumstances; thus, it returned a death sentence. Appellant raised thirteen claims on appeal pertaining to errors at trial, the sufficiency of the evidence presented against him, and ineffective assistance of trial counsel. The Supreme Court found no merit to Appellant's claims, and affirmed his conviction and death sentence. View "Pennsylvania v. Philistin" on Justia Law