Justia Pennsylvania Supreme Court Opinion Summaries

The issue on appeal before the Supreme Court in this case was whether sheriffs and their deputies have the independent authority to establish and conduct suspicionless roadside sobriety checkpoints. In 2007, sheriffs and deputies of the Forest and Wayne County Sheriffs' Departments established temporary checkpoints in Forest County. Appellee drove a vehicle into the checkpoint, was stopped, was found to have used alcohol, and underwent a field sobriety and chemical test. Based on the results, he was arrested and charged with DUI and other offenses. "The members of [the Supreme Court] maintain great respect and express gratitude for sheriffs and their deputies in the performance of indispensable public services within their realm. We reiterate, however, that they are not police officers - nor are they invested with general police powers beyond the authority to arrest for in-presence breaches of the peace and felonies - in the absence of express legislative designation." The Court held that the sheriffs did not have the authority to independently establish and conduct the suspicionless sobriety checkpoint at which Appellee was arrested. View "Pennsylvania v. Marconi" on Justia Law

The Commonwealth appealed an order of the Court of Common Pleas of Allegheny County which granted Appellee Connie Williams' Post-Conviction Relief Act (PCRA) petition and vacated his sentence of death on the basis that appellee demonstrated, by a preponderance of the evidence, that he was mentally retarded. A jury convicted appellee of first degree murder and abuse of a corpse for stabbing his wife, Frances Williams, to death. The Supreme Court found that the PCRA court's factual findings were supported by substantial evidence, and its legal conclusions drawn therefrom were free from error. Accordingly, the Supreme Court affirmed. View "Pennsylvania v. Williams" on Justia Law

The Commonwealth appealed a superior curt order that affirmed a trial court's grant of post-conviction relief (pursuant to the Post Conviction Relief Act (PCRA)). The lower courts held that appellee's trial counsel was ineffective for failing to challenge jury instructions at his 1993 trial for first-degree murder and related charges. The superior court concluded the jury charge at issue violated "Commonwealth v. Huffman," (638 A.2d 961 (Pa. 1994)). On appeal, the Commonwealth argued that in deeming counsel ineffective, the lower courts failed to account for the Supreme Court's more recent case law that effectively overruled "Huffman." Upon review, the Supreme Court concluded that the panel failed to appreciate basic distinctions between this case and the Huffman case, "distinctions made clearer by subsequent decisional law the panel failed to consider." Accordingly, the Supreme Court reversed the order of the Superior Court and remanded the case to the PCRA court for the entry of an order denying appellee PCRA relief. View "Pennsylvania v. Bennett" on Justia Law

Appellant James Baldwin appealed a superior court order that affirmed his sentence for first degree murder and abuse of a corpse. Finding that the trial court did not abuse its discretion in denying appellant's request to testify on his own behalf after the evidentiary phase of the trial was closed, and after he waived such right the previous day, the Supreme Court affirmed. View "Pennsylvania v. Baldwin" on Justia Law

The issue in this discretionary appeal was whether a police officer violates the Pennsylvania Wiretapping and Electronic Surveillance Act ("Wiretap Act" or "Act") when he communicates directly with a suspect via cell phone text messages while pretending to be the suspect's accomplice. "Because an officer who directly communicates with another person by text-messaging is not eavesdropping or listening in on a conversation, but is himself engaging in the communication, and because for purposes of the Wiretap Act, it is irrelevant that an officer intentionally misrepresents his identity to the person with whom he communicates," the Supreme Court held that no violation of the Wiretap Act occurred in this case. View "Pennsylvania v. Cruttenden" on Justia Law

The Supreme Court addressed cross-appeals in this opinion, arising from a capital matter from an order of the Court of Common Pleas of Philadelphia County. The lower court granted partial relief under the Post Conviction Relief Act (PCRA), which the Commonwealth appealed insofar as it granted relief on Appellee Jose DeJesus's claim that he was ineligible for the death penalty under "Atkins v. Virginia," (536 U.S. 304 (2002)), because he was mentally retarded. Appellee cross-appealed the PCRA court's concurrent denial of his various other PCRA claims. At trial, before the court issued a decision on Appellee's "Atkins" claim, the Commonwealth filed a motion to reopen the record, asserting that it had recently received information from prison officials that she substantial doubt on appellee's claims of mental retardation. The PCRA Court denied the Commonwealth's motion, offering no further explanation or discussion for the denial. The PCRA court concluded that appellee had met his burden to prove limited intellectual functioning. In the court's view, the Commonwealth's evidence and argument that appellee malingered on his post-Atkins tests, while "compelling," did not "carry the day." The PCRA court also addressed the merits of the claims raised by appellee in his cross-appeal, rejecting them all. The Supreme Court concluded the PCRA Court abused its discretion in not entertaining the Commonwealth's new evidence. "The Commonwealth's proffer specified that this evidence was relevant to the intellectual and adaptive function elements of Atkins because it showed appellee's ability, not only to function within prison, but to use his wits and skills to 'beat the system' in a manner that required forethought, direction and coordination of others." The Supreme Court vacated the PCRA court's decision and accompanying order which found appellee mentally retarded and vacated his death sentences, but otherwise denied relief. This matter was remanded for further Atkins proceedings. View "Pennsylvania v. DeJesus" on Justia Law

The Commonwealth appealed a superior court order that reversed an order denying appellee's petition for post conviction relief and for remanding for an evidentiary hearing. Appellee Joseph Abraham was accused of soliciting a former student for sex, and for allegedly sexually assaulting her. When the allegations surfaced, the then 67-year-old Appellee retired from teaching and began receiving pension payments. Pursuant to a negotiated agreement, appellee pled guilty to corruption of a minor and indecent assault of a person less than 16 years of age. He was sentenced to probation; no direct appeal was filed. Because the crime of indecent assault of a person less than 16 years of age is one of the enumerated offenses in the Public Employee Pension Forfeiture Act (PEPFA), appellee forfeited his pension when he pled guilty to this charge. He filed a motion to withdraw his plea nunc pro tunc, alleging he was not informed of his right to seek withdrawal of his plea or of the possible sentences he faced. The trial court denied the motion. Appellee filed a timely PCRA petition alleging plea counsel was ineffective for failing to inform him he would forfeit his pension upon pleading guilty. The PCRA court dismissed the petition without a hearing. On appeal, the Superior Court reversed. "Because counsel cannot be deemed ineffective for failing to advise a defendant regarding the collateral consequences of a plea, appellee's ineffectiveness claim fails." Therefore, the Supreme Court reversed the order of the Superior Court granting appellee a PCRA hearing on the issue of prejudice, and remanded the case to reinstate the PCRA court's order denying appellee relief. View "Pennsylvania v. Abraham" on Justia Law

Appellant filed a pro se PCRA petition in 2006 to appeal his murder conviction. The Federal Community Defender Office ("FCDO"), Capital Habeas Unit unilaterally entered its appearance.on Appellant's behalf. Federal counsel filed a lengthy amended petition, alleging numerous claims of trial court error and ineffective assistance of counsel. The PCRA court conducted an evidentiary hearing over four separate days. Following the hearing, the court denied relief. Appellant then appealed to the Supreme Court. Appellant's issues on appeal, as summarized by the Court: (1) whether counsel was ineffective in failing to investigate and present mental health evidence to support claims of diminished mental capacity, imperfect belief of defense of others, and mitigating evidence; (2) whether counsel was ineffective in failing to challenge the Commonwealth’s peremptory challenges of potential jurors; (3) whether counsel was ineffective in failing to properly question potential jurors who were excused because they expressed doubts about imposing the death penalty; (4) whether counsel was ineffective in challenging appellant’s inculpatory statements; (5) whether the jury was presented with materially false evidence by the Commonwealth and whether trial counsel was ineffective for failing to present an expert to dispute this evidence; (6) whether counsel was ineffective in failing to object to victim impact evidence; (7) whether error in the guilt phase jury instructions violated appellant’s due process rights; (8) whether counsel had a conflict of interest; (9) whether appellant’s rights were violated because no transcript existed of portions of his trial; and (10) whether the cumulative effect of the alleged errors warranted relief. After thorough review of Appellant's claims, the Supreme Court affirmed the PCRA court insofar as it dismissed all claims other than that of ineffective assistance of counsel associated with the investigation, development, and presentation of mitigation evidence. With respect to this claim, the PCRA court's order was vacated, and the matter was remanded for further consideration. View "Pennsylvania v. Sepulveda" on Justia Law

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