Justia Pennsylvania Supreme Court Opinion Summaries

In this discretionary appeal, the Supreme Court considered whether under Pennsylvania’s Juvenile Act, a juvenile court is required to enter on the record an adjudication of delinquency once it has determined the juvenile committed the acts alleged in the delinquency petition, or whether the court must make an additional finding that the juvenile is in need of treatment, supervision, or rehabilitation, prior to entering an adjudication of delinquency. In 2007, the Commonwealth filed a delinquency petition against M.W. alleging that he and another youth robbed an individual who had just left a local bar. At an adjudicatory hearing, the juvenile court found that M.W. committed robbery, conspiracy, and related charges. Later that same day, M.W. was adjudicated delinquent by another juvenile court judge on a separate delinquency theft petition, and M.W. was committed for treatment, rehabilitation, and supervision. After a hearing on the first petition, the trial court discharged the delinquency petition stemming from the robbery offense, noting that M.W. "will be adjudicated on the [theft] petition. He will still receive treatment and supervision." The Commonwealth filed a motion for reconsideration, which was denied. The Commonwealth then appealed to the Superior Court, where it argued that the juvenile court abused its discretion and violated the requirements of the Juvenile Act by failing to adjudicate M.W. delinquent once it found that M.W. had committed the acts alleged in the original delinquency petition. Upon review, the Court held that the Juvenile Act requires a juvenile court to find both: (1) that the juvenile has committed a delinquent act; and (2) that the juvenile is in need of treatment, supervision, or rehabilitation, before the juvenile court may enter an adjudication of delinquency. In this case, the Court reversed the decision of the Superior Court. View "Pennsylvania v. In the Interest of M.W." on Justia Law

Appellant John Koehler appealed a common pleas court order that dismissed his petition for collateral relief filed under the Post Conviction Relief Act (PCRA). Appellant was convicted for the murder of Regina Clark and her nine-year old son Austin for which he was sentenced to death. On appeal, Appellant raised nineteen issues that primarily challenged the effectiveness of his trial counsel. The PCRA court denied Appellant relief, finding that while he raised nineteen issues, Appellant pursued only three before the court. On direct appeal to the Supreme Court, Appellant raised thirteen issues, again pertaining to the effectiveness of his trial counsel. The Court noted that Appellant's trial counsel was the same as it was for his direct appeal. Finding none of Appellant's issues on appeal meritorious, the Court affirmed the PCRA court's order that dismissed Appellant's PCRA petition. View "Pennsylvania v. Koehler" on Justia Law

This case was remanded from the federal Supreme Court who vacated the Pennsylvania court's prior decision in light of "Michigan v. Bryant" (131 S.Ct. 1143 (2011)). In 2004, Appellant Ricky Lee Allshouse and "M.R." were arguing in the home they shared with their three children. The argument ended with rushing their seven-month old son to the hospital for a spiral fracture to his right humerus caused by a sharp and severe twisting of his arm. The infant's four-year-old sister implicated Appellant in the incident, and he was later arrested and charged with aggravated assault, simple assault, endangering the welfare of a child, reckless endangerment and harassment. Ultimately Appellant was sentenced to one to two years in prison. On appeal, Appellant argued that the trial court's admission of the daughter's statement to a psychologist violated his constitutional rights. Thereafter, he appealed to the U.S. Supreme Court. The threshold question in this case was whether the daughter's statements were "testimonial;" if they were nontestimonial, "the confrontation clause places no restriction on their introduction except for 'the traditional limitations upon hearsay evidence.'" The Superior Court concluded that the dauther's statement to the psychologist was nontestimonial under because (a) the doctor's intent during his interview with the daughter was not to obtain testimony for the purpose of a criminal proceeding, but to ensure the safety of the infant and his siblings, and (b) the environment and circumstances surrounding her statement were informal and not suggestive of an investigatory interview. The Court affirmed the Superior Court's decision to admit the daughter's statements. View "Pennsylvania v. Allshouse, Jr." on Justia Law

Appellee Antoine Miller brutally murdered Wallace Bivens in his home, then stole his car. Appellee was arrested later that evening after police noticed him driving the car without headlights. Appellee then engaged in a high-speed chase. Appellee was charged with multiple Motor Vehicle Code violations, and police impounded the car. While attempting to serve an eviction notice on the victim, a state constable discovered the victim's decaying body in the living room closet of his apartment. Appellee was later apprehended and charged with first-, second- and third-degree murder, robbery, aggravated and simple assault, theft, and a host of other crimes. Appellee was found guilty of second-degree murder, theft by unlawful taking, and fleeing or attempting to elude an officer, and acquitted of first-degree murder, robbery, aggravated assault and possessing an instrument of crime.Appellant appealed to the Superior Court, contending that the evidence was insufficient to sustain his second-degree murder conviction because he had been acquitted of the predicate offense of robbery. The Superior Court reversed Appellee's second-degree murder conviction and vacated his judgment of sentence. The question presented for the Supreme Court's review implicated the issue of inconsistent verdicts in the context of a second-degree murder conviction. Because the Superior Court erroneously concluded that a jury's verdict of guilt on a second-degree murder charge and its acquittal on the predicate felony of robbery were impermissibly inconsistent and could not stand, the Court vacated the Superior Court's order. View "Pennsylvania v. Miller" on Justia Law

Brothers-Appellees Gerald and Louis Garzone are licensed funeral home directors in Philadelphia. They contracted with a business that sold human cadavers and harvested tissue for resale and medical use. The arrangement was undertaken without the knowledge or consent of the families of the deceased and continued through September 2005, at which point Michael Mastromarino, owner of Biomedical Tissue Services, learned that the Food and Drug Administration (FDA) was investigating him. Mastromarino advised Appellees to destroy their records days before FDA investigators arrived. A grand jury charged Appellees with 244 counts of theft by unlawful taking (of body parts), abuse of corpses, and various other charges. Appellees informed the Commonwealth that they intended to continue to trial, even knowing that all other codefendants intended to plead guilty and cooperate with the Commonwealth. The Commonwealth prepared for trial, but on the scheduled trial date, Appellees pleaded guilty to all charges. At sentencing, the Commonwealth asked if the court would "consider requiring the defendants to pay cost[s] of prosecution or a portion," arguing that its personnel had to devote extensive resources and hours to prepare for a long trial. The issue on appeal to the Supreme Court was whether a trial court may order a convicted offender to pay the costs of the Commonwealth (for the sum total of salaries of the attorneys, investigators and other officials involved in preparing for trial). The Superior Court vacated the trial court’s imposition of such costs. The Supreme Court reversed the Superior Court: "Although our reasoning does not track that of the panel below, we are in agreement with its central holding that, "[a]lthough the crimes in this case are particularly heinous, if the General Assembly intended to permit such recovery of regularly paid salaries of assistant district attorneys and detectives to be costs associated with the prosecution, the Legislature would have expressly done so." View "Pennsylvania v. Garzone" on Justia Law

Appellant Ernest Porter appealed a common pleas court order that denied his serial petition under the Post Conviction Relief Act (PCRA). Appellant was sentenced to death for the murder of Raymond Fiss in 1985. After his appeal was was briefed on the timeliness merits and submitted, the parties, upon direction of the Supreme Court, filed supplemental briefs addressing the jurisdictional issue of whether the PCRA court's order was final and appealable. Upon review, the Supreme Court determined that the common pleas court's order was appealable and that the court's time-bar determination was correct. With this case, the Supreme Court took the opportunity to address: (1) the circumstances creating uncertainty respecting appealability, in an effort to ensure that those circumstances do not arise again; and (2) the circumstances creating the unacceptable delay in this case, so that PCRA courts throughout Pennsylvania will take measures to avoid such delays. Though the Court affirmed the PCRA court's decision with regard to the time-bar determination, the case was remanded to direct the PCRA court to promptly dispose of Appellant's long-pending prior PCRA petition which raised an issue under "Atkins v. Virginia," 536 U.S. 304 (2002). View "Pennsylvania v. Porter" on Justia Law

Appellant Abraham Sanchez, Jr. appealed his death sentence, raising eight claims of trial court error regarding aspects of the guilt and penalty phases of his trial, including a challenge to the timing and the use of the jury in adjudicating his claim of death penalty ineligibility under "Atkins v. Virginia," 536 U.S. 304 (2002). Appellant challenged the sufficiency of the evidence presented against him at trial, and sought an acquittal. Upon careful consideration of Appellant's arguments on appeal, the Supreme Court found the evidence was sufficient to convict him and to support they jury's death sentence. The Court found that Appellant was not entitled to an acquittal, and affirmed his conviction. View "Pennsylvania v. Sanchez" on Justia Law

Appellant David Ramtahal appealed his death sentence following his first-degree murder, conspiracy, possession of an instrument of crime and robbery convictions. On appeal to the Supreme Court, Appellant argued that: (1) the evidence was insufficient to convict him of first-degree murder; (2) the verdict was contrary to the weight of the evidence; (3) the trial court abused its discretion in limiting cross-examination of a prosecution witness; and (4) a new penalty hearing is warranted because the jury failed to specify what considerations prompted it to find the mitigating circumstance codified by law. Finding that None of Appellants claims merited relief, the Supreme Court found that Appellant's sentence was supported by sufficient evidence, including the aggravating factors determined by the jury. Accordingly, the Court affirmed Appellant's death sentence. View "Pennsylvania v. Ramtahal" on Justia Law

Appellee Raymond Haun was convicted on multiple sexual offenses for which he received a 27 to 97 year sentence in prison. Approximately one year after he was convicted, Appellee sought relief under the PCRA, arguing his trial attorney failed to contest his sentence despite his explicit request for counsel to do so. After testifying to the court regarding his wish to appeal, on cross-examination, the Commonwealth set out to elicit an admission that Appellee had committed the criminal acts for which he was convicted. The PCRA court overruled an objection to the line of questioning. Appellee then responded that he did, in fact, commit the offenses. Furthermore, he acknowledged that he previously admitted his guilt during the presentence investigation, at sentencing and in the assessment process required under Megan's Law. When asked why he wished to appeal his sentence, Appellee responded that he believed the length of his sentence was unfair. The issue before the Supreme Court was whether Appellee's confession of guilt foreclosed his access to judicial review under the Post Conviction Relief Act. The Commonwealth asked the Supreme Court to revisit its holding in "Commonwealth v. Lantzy" (735 A.2d 564 (1999)) and adopt the superior court's decision which "Lantzy" reversed. "In its brief, the Commonwealth has provided [the Court] with nothing to suggest that [the Court] was wrong in Lantzy... [the Court declined] to effectively overrule [its] decision based on a presentation which refuses to come to terms with [its] opinion's governing rationale." The Court held that a concession of guilt did not per se foreclose prisoner access to the PCRA. View "Pennsylvania v. Haun" on Justia Law

Appellant Shawn Walker appealed the dismissal of his motion for a new trial. In 1991, Appellant forcibly entered the home of his former girlfriend, shot and killed a man sleeping on the couch, and shot and permanently disabled the girlfriend. After finding two aggravating factors, the jury convicted Appellant of first degree murder and sentenced him to death. Appellant filed a pro se PCRA petition, raising numerous issues on appeal. Among them, Appellant claimed he received ineffective assistance of counsel because his trial counsel allegedly failed to present specific mitigation evidence. Upon careful review of the trial court and PCRA court records, the Supreme Court concluded that Appellant failed to establish that any of his claims entitled him to a new trial. Accordingly, the Court affirmed Appellant's conviction and sentence. View "Pennsylvania v. Walker" on Justia Law