Justia Pennsylvania Supreme Court Opinion Summaries

On November 17, 2017, Patrolman Brian Shaw of the City of New Kensington Police Department was shot and killed in the line of duty. At 8:06 p.m. Officer Shaw informed dispatch that a vehicle had failed to stop for his lights and sirens. Shortly afterwards, Officer Shaw announced that he was pursuing on foot. Moments later he radioed that he had been shot. Because no one witnessed the shooting, the Commonwealth established appellant Rahmel Sal Holt’s guilt through circumstantial evidence, including the testimony of Tavon Harper, the driver of the vehicle Officer Shaw attempted to stop. Holt would ultimately be convicted, for which he was sentenced to death. Appeal to the Pennsylvania Supreme Court was automatic. Finding no reversible error, the Supreme Court affirmed the sentence. View "Pennsylvania v. Holt" on Justia Law

Appellant Michael Parrish appealed after the Court of Common Pleas of Monroe County dismissed his petition for post-conviction relief filed pursuant to the Post Conviction Relief Act (“PCRA”). To the Pennsylvania Supreme Court, Parrish raised numerous claims of error, including a layered ineffectiveness claim in connection with the failure of trial counsel to file a notice of appeal after his conviction and death sentence. The first layer of his claim was the contention that trial counsel were ineffective for not consulting with him regarding his appellate rights before failing to file a notice of appeal, and in so doing, violated a constitutional duty established in Roe v. Flores-Ortega, 528 U.S. 470 (2000). The second layer of the claim was Parrish’s assertion that his initial PCRA counsel’s stewardship of the failure to consult claim before the PCRA court was deficient, in that initial PCRA counsel failed to present any evidence or legal argument to substantiate the failure to consult claim. In his brief to the Pennsylvania Supreme Court, Parrish identified the evidence and legal theory that his initial PCRA counsel should have presented to the PCRA court. Parrish raised the second layer of his claim for the first time to the Supreme Court in this appeal, and the Supreme Court concluded he was permitted to do so without a finding of waiver based upon a recent decision in Commonwealth v. Bradley, 261 A.3d 381 (Pa. 2021). Accordingly, the Supreme Court remanded this case for the introduction of evidence and legal argument so that the PCRA court could issue a decision on the merits of Parrish’s layered failure to consult claim. View "Pennsylvania v. Parrish" on Justia Law

The Pennsylvania Supreme Court granted allowance of appeal in this matter to determine whether its reasoning in Commonwealth v. Johnson, 231 A.3d 807 (Pa. 2020) applied to preclude the retrial of Appellant Derrick Edwards on double jeopardy principles where the prosecutor acted with discriminatory intent when exercising a peremptory strike of an African American juror in violation of Batson v. Kentucky, 476 U.S. 79 (1986). After review, the Court held that the prosecutor’s violation of Batson under the circumstances presented did not preclude the retrial of Appellant. Accordingly, the Supreme Court affirmed the Superior Court, which affirmed the trial court’s order denying Appellant’s motion to dismiss the charges against him on double jeopardy grounds. View "Pennsylvania v. Edwards" on Justia Law

In 2009, when he was seventeen-and-a-half years old, appellant Michael Felder was playing in a pick-up basketball game with Andrew Williams at an outdoor court in Philadelphia. The pair were matched against brothers Jarrett and Malcolm Green. Appellant’s style of play became aggressive; an argument ensued after Williams refused to hand the ball over to the Greens. Appellant walked to the sideline and removed a .380 semiautomatic handgun from his gym bag, and shot Malcolm in the head before shooting Jarrett in the stomach and leg. A jury convicted appellant of first-degree murder and aggravated assault. Pursuant to the then-applicable mandatory sentence for first-degree murder, which also applied to juveniles, appellant was sentenced to life imprisonment without the possibility of parole. The Superior Court vacated appellant’s judgment of sentence two years later; by then, Miller v. Alabama, 567 U.S. 460 (2012) and Commonwealth v. Batts, 66 A.3d 286 (Pa. 2013) (“Batts I”) had been decided. Since appellant’s judgment of sentence was not yet final, the Superior Court determined he was entitled to the benefit of those rulings and to consideration of the Miller factors before being resentenced, and remanded the case for such proceedings. Upon remand, the court imposed a discretionary 50-years-to-life sentence for appellant’s first-degree murder conviction. On appeal to the Superior Court, appellant challenged the legality of his sentence, arguing “a 50-year minimum sentence is a de facto life sentence.” The Superior Court found that although the sentence precluded appellant from seeking parole until he was 68 years old, it was constitutional because it “was the result of an individualized and discretionary sentencing hearing[.]” The Pennsylvania Supreme Court granted discretionary review limited to whether appellant's sentence was indeed a de facto life sentence requiring the sentencing court under Commonwealth v. Batts, 163 A.3d 410 (Pa. 2017) (“Batts II”), "[to] first find permanent incorrigibility, irreparable corruption or irretrievable depravity beyond a reasonable doubt." The Supreme Court determined Jones v. Mississippi, 141 S.Ct. 1307 (2021) "abrogates our foundational understanding in Batts II." So long as the sentence imposed is discretionary and takes into account the offender’s youth, even if it amounts to a de facto life sentence, Miller is not violated. "Because the sentencing court in the present case followed this procedure, we affirm." View "Pennsylvania v. Felder" on Justia Law

As a result of a vehicle search, the Commonwealth discovered a bag of marijuana and a firearm. In connection with these items, the Commonwealth charged Appellant Timothy Barr, II with: persons not to possess a firearm, possession of a firearm without a license, and possession of a small amount of marijuana. Appellant filed an omnibus pretrial motion, which included a motion to suppress the physical evidence gathered by police during the search, and a petition for a writ of habeas corpus, contending that the Commonwealth could not establish a prima facie case that Appellant possessed a small amount of marijuana or committed the firearm offenses. The trial court granted the motion to suppress and granted in part the petition for a writ of habeas corpus, dismissing the count of possession of a small amount of marijuana. The Pennsylvania Supreme Court granted allowance of appeal in this matter to examine to what extent, if at all, the smell of marijuana could be considered when determining whether law enforcement had probable cause to conduct a warrantless search of a vehicle. This issue arose in light of the Pennsylvania General Assembly’s enactment of the Medical Marijuana Act, which legalized the possession and use of marijuana in limited circumstances, and the Court’s recent decision in Commonwealth v. Hicks, 208 A.3d 916 (Pa. 2019), which addressed whether police could stop and frisk a person merely based on the fact that the person possessed a concealed firearm in public. Like the Superior Court, the Supreme Court held that the smell of marijuana could be a factor, but not a stand-alone one, in determining whether the totality of the circumstances established probable cause to permit a police officer to conduct a warrantless search of a vehicle. The Court disagreed with the Superior Court’s decision to remand the matter to the trial court for reconsideration of its order granting the motion to suppress filed by Timothy Barr, II (“Appellant”). Instead, that portion of the Superior Court's decision was vacated, the trial court's judgment reinstated (granting Appellant’s motion to suppress), and remanded for further proceedings. View "Pennsylvania v. Barr" on Justia Law

In 1983, David Santana was convicted of rape in New York. At the time, neither New York nor Pennsylvania had enacted a sex offender registration scheme. However, as time passed, states began enacting statutory schemes aimed at monitoring sexual offenders by requiring them to comply with strict registration and notification requirements. In 1995, New York passed the “Sex Offender Registration Act” (“SORA”), which became effective in January 1996. Pennsylvania followed suit, enacting the first version of Megan’s Law in 1995. In this case, the issue presented for the Pennsylvania Supreme Court's review centered on whether its decision in Commonwealth v. Muniz (holding that SORNA constituted a punitive regulatory scheme that, when imposed retroactively to sex offenders who committed their offenses prior to SORNA’s enactment, amounted to an unconstitutional ex post-facto law) applied with equal force to offenders whose triggering offenses occurred in another state. The Supreme Court concluded that it did, thereby affirming the Superior Court. View "Pennsylvania v. Santana" on Justia Law

This appeal arose from the prosecution of two defendants in connection with alleged hazing rituals at Penn State University in 2016 and 2017 that led to the death of Timothy Piazza. The prosecutions proceeded at multiple docket numbers for each defendant, and although the common pleas court consolidated the docket numbers for trial, the docket numbers were not consolidated for all purposes. Defense suppression motions were granted in part and the Commonwealth filed two interlocutory appeals, one for each defendant. The notice of appeal for each defendant contained all docket numbers pertaining to that defendant. The Superior Court determined separate notices of appeal should have been filed for each docket number and quashed the appeals pursuant to the Pennsylvania Supreme Court’s ruling in Commonwealth v. Walker, 185 A.3d 969, 976 (Pa. 2018). The Supreme Court granted review to examine whether the intermediate court correctly applied the holding in Walker considering the Commonwealth’s position the matter was more properly controlled by Always Busy Consulting, LLC v. Babford & Co., Inc., 247 A.3d 1033 (Pa. 2021) The Supreme Court concluded the exception to the Walker rule enunciated in "ABC" was not broad enough to encompass this appeal. Nevertheless, the Supreme Court remanded to the Superior Court to determine, in its discretion, whether the Commonwealth should have been granted relief through application of the safe harbor provision of Pa.R.A.P. 902. View "Pennsylvania v. Young" on Justia Law

In March 2016, Christa Nesbitt was working as a server at the Whistle Stop diner in Oreland, Pennsylvania, when she first met Daniel Talley. Over the next several months, their friendly chats led to mutual affection, which then evolved into an intimate and physical relationship. In September 2016, Talley asked Nesbitt and her minor daughter, R.N., to move into his home. Nesbitt agreed. She and R.N. lived with Talley until the spring of 2017. At the end of May 2017, Nesbitt and R.N. moved out of Talley’s house. The next day, Nesbitt began receiving threatening and harassing messages on her mobile phone from unfamiliar email addresses. Nesbitt ultimately reported the threats to police, by August, Talley was arrested for aggravated assault, stalking, harassment and related offenses. The Pennsylvania Supreme Court granted review of this matter to resolve two distinct legal issues: (1) the Commonwealth’s burden of proof when it seeks to deprive the accused of his or her state constitutional right to bail; and (2) whether the best-evidence rule allows a party to introduce printed photographs of text messages as they appeared on a cellphone’s interface—i.e., “screenshots.” The Supreme Court found that while the trial court committed an error of law in denying Talley’s motion for release on nominal bail, Talley was due no relief because he failed to prove that the error affected the outcome of his trial. Nor was a new trial warranted on his best-evidence claim, since the lower courts concluded correctly that the screenshots of the text messages were admissible duplicates. View "Pennsylvania v. Talley" on Justia Law

Appellant Joseph McCabe was arrested on charges of theft by unlawful taking and receiving stolen property in connection with the April 2015 taking of a collection of gold coins from the home of Thomas and Kathy Mohn, with whom Appellant had been staying. Montgomery County had instituted a Veterans Treatment Court (VTC) Program in 2011; Appellant applied for participation in the VTC and was accepted into the program. As a condition thereof, he entered an open plea to the theft charge graded as a third-degree felony. The VTC’s order accepting the plea noted that sentence would be deferred and, as a condition, that a restitution hearing would be scheduled. Appellant successfully completed the requirements and conditions of the VTC program. The court reviewed the sentencing guidelines and acknowledged Appellant’s success in the VTC program, and sentenced Appellant to a two-year term of probation. Appellant moved for reconsideration of the sentence, which was ultimately denied. The Pennsylvania Supreme Court granted certiorari review in this case to determine whether a problem-solving court like the VTC, was subject to to Chapter 3 of the Pennsylvania Rules of Criminal Procedure (the Rules) governing Accelerated Rehabilitative Disposition (ARD). The Court also considered whether Appellant, due to his inability to fully pay restitution, was denied the full benefit of the problem-solving court in contravention of his rights to due process and equal protection under the Fourteenth Amendment of the United States Constitution. The Supreme Court found positive sentencing consideration, including dismissal of charges, could accompany a successful completion of the program, but the program did not create guarantees, procedures, or discretion not already authorized under the Rules. Accordingly, the Supreme Court affirmed the Superior Court’s determination that the trial court’s sentencing order regarding restitution was not governed by Chapter 3 of the Rules. The Court also affirmed the judgments of the lower courts, finding no as-applied constitutional infirmities to have been established in Appellant’s claim. View "Pennsylvania v. McCabe" on Justia Law

During the investigation, officers obtained a warrant to search for evidence of possession and distribution of child pornography on the electronic devices in the home of Appellant, Eric Green. The Pennsylvania Supreme Court granted review in this matter to address whether that search warrant was overbroad. After careful consideration, the Court found no reversible error with the lower courts' determinations that the warrant was not overbroad because it described the physical devices and digital data for which there was probable cause as nearly as may be under the circumstances. Accordingly, the Superior Court judgment was affirmed. View "Pennsylvania v. Green" on Justia Law