Justia Pennsylvania Supreme Court Opinion Summaries

In this capital case, Appellant Ronald Hanible appealed an order of the Court of Common Pleas of Philadelphia County (PCRA court) which denied without a hearing all guilt phase claims raised in his petition for post-conviction relief. Appellant was convicted on two counts of murder. Appellant did not testify on his own behalf or present any witnesses at trial. Instead, he urged the jury to reject the Commonwealth's key witness' testimony as unreliable. Appellant further argued to the jury that none of the physical evidence recovered by police implicated him in the crime. Following the penalty hearing, the jury found two aggravating circumstances and no mitigating circumstances. Accordingly, it returned a verdict of death. Appellant filed a pro se PCRA petition and was appointed counsel. The PCRA court granted a new penalty hearing based on evidence that Appellant's trial counsel failed to present available mitigating evidence. Appellant raised sixteen issues for review to the Supreme Court based on the PCRA's dismissal of his relief petition. The Supreme Court took each in turn, and ultimately affirmed the PCRA court's decision to deny Appellant the relief he requested. View "Pennsylvania v. Hanible" on Justia Law

In this discretionary appeal, the Supreme Court reviewed the lower courts' application of the "totality of the circumstances" test for the existence of probable cause necessary to issue a search warrant as set forth by the U.S. Supreme Court in "Illinois v. Gates" and adopted by Pennsylvania in "Commonwealth v. Gray." Specifically, the Court questioned whether the lower courts properly applied the test in determining whether a search warrant was infirm because the affidavit of probable cause failed to expressly attest to the veracity, reliability and basis of knowledge of a confidential informant. Because the totality of the circumstances applied by the trial court in Appellee Steven Clark's case included a factual recitation describing a successful controlled buy of narcotics that corroborated the affiant's averment that the informant was reliable, and because that recitation demonstrated a fair probability that narcotics would be found in the location for which the warrant was sought, the Court determined that the warrant was supported by probable cause. The Court found that the appellate court's suppression of evidence was contrary to its holding here, reversed that court, and remanded the case to the trial court for further proceedings consistent with this opinion. View "Pennsylvania v. Clark" on Justia Law

Appellant Terry Chamberlain appealed the death sentence imposed on him after a jury convicted him of two counts of first-degree murder, burglary and possessing "an instrument of crime" in 1994. On direct appeal, the Supreme Court held that the trial court abused its discretion in denying a pretrial motion for a continuance to allow Appellant to obtain DNA testing of certain blood evidence. The case was remanded for the trial court to allow Appellant to do the testing. The trial court completed proceedings on remand, and the case went back to the Supreme Court for its consideration on the remaining claims in Appellant's appeal. Upon review of those claims, the Court affirmed Appellant's death sentence. View "Pennsylvania v. Chamberlain" on Justia Law

The Supreme Court considered the effect of a pro se notice of appeal which was forwarded to the superior court by a counseled criminal defendant, where counsel, who was not made aware of the pro se notice, subsequently filed a timely post-sentence motion which was denied by the trial court, and then a second timely notice of appeal. In this case, the superior court administratively quashed the counseled-appeal as duplicative, then quashed Appellee Michael Cooper's pro se appeal as premature and void. Yet the court also remanded the case to the trial court for additional review of the counseled post-sentence motion. Upon review, the Supreme Court held that the superior court erred in quashing the appeal and remanding the counseled post-sentencing motion. Therefore, the Court vacated the order and remanded the case back to the superior court for consideration of the merits of Appellee's direct appeal. View "Pennsylvania v. Cooper" on Justia Law

n this appeal, the issue before the Supreme Court was whether the mere offer of an automobile ride to a child constituted an attempt to “lure” the child under Section 2910 of Pennsylvania’s Criminal Code, entitled “Luring a child into a motor vehicle or structure.” Appellant was charged with four counts of harassment, stalking, and attempted luring of a child into a motor vehicle for offering two neighborhood boys a ride to school in Appellant's own neighborhood. He had seen the children in the neighborhood, and offered them short rides to school or to the store. The children declined, and Appellant made no further attempt to "help." Appellant was acquitted of the charged at a bench trial because the judge "expressly stated she found no evidence that Appellant had any intent to harm the children, and that she believed 'the circumstances show no reason to believe that this defendant had any evil or improper intent in doing what he did.'” However, on the sole basis of Appellant’s offer of the rides, she convicted him on all four counts of attempted luring. The trial court found that “[Appellant’s] offer of a ride to the victims is sufficient to constitute an attempt to ‘lure.’” The trial court subsequently sentenced Appellant to 18 months’ probation. As an automatic result of his convictions, Appellant was statutorily mandated to register for ten years as a sex offender under Megan’s Law. Appellant filed an appeal to the Superior Court, arguing that the evidence was insufficient as a matter of law to sustain his conviction, because his offer of a ride to the children, by itself, did not constitute a “lure” or an attempt to “lure,” given that he did not offer the children any enticement to get into his car, nor did he command or otherwise threaten them. Appellant also argued that he had no ill intent in offering the children a ride, but, rather, was merely acting as a “disabled Good Samaritan.” After careful review, the Supreme Court concluded that an attempt to “lure” does not include the action of simply extending an offer of an automobile ride to a child, when it is unaccompanied by any other enticement or inducement for the child to enter the motor vehicle. Consequently, the Court reversed Appellant's conviction for attempted luring. View "Pennsylvania v. Hart" on Justia Law

Appellant Michael Travaglia appealed his death sentence imposed by the Westmoreland County Court of Common Pleas following a penalty hearing held pursuant to a grant of federal habeas corpus relief. Appellant was convicted in the shooting death of an Apollo police officer in 1980. Prior to the officer's homicide, state police received information indicating that Appellant was involved in a number of armed robberies and killings in Pittsburgh and surrounding counties. Appellant would later give a statement to police implicating himself in the killing of the officer and several others. Following the denial of his post-sentence motions Appellant appealed to the Supreme Court where he raised eighteen alleged errors in his penalty hearing. The Supreme Court took each issue in turn and ultimately affirmed Appellant's death sentence. View "Pennsylvania v. Travaglia" on Justia Law

Sean Pearce was bicycling along a road when he collided with a construction barrel and fell into the road. At least two vehicles, one driven by Appellee Gregory Wisneski, subsequently fatally struck Pearce. Appellee later admitted driving along the road when, initially thinking he hit a speed bump, he looked in his mirror and saw a body in the road. Appellee did not stop at the scene. The Commonwealth charged Appellee with failing to stop at an accident, failing to comply with a duty to give information and render aid, and failing to immediately notify the police. Appellee filed a habeas petition seeking dismissal of the charges, arguing the Commonwealth could not prove Pearce was alive when Appellee struck him. The trial court concluded that the statutes required the victim to be alive at the time of the accident, reasoning that "once a victim of an accident is dead, the accident concludes that the statutes cannot apply to vehicles that later come upon the scene." A divided Superior Court affirmed the trial court's dismissal of the information against Appellee. Upon review, the Supreme Court found that "a person does not turn into mere property upon their death, certainly not for purposes of a driver's obligations under the Vehicle Code. We find, therefore, the term 'resulting in injury' must include causing harm or damage to the body of a human, whether deceased or not. To find otherwise would defeat the legislative scheme, and would be offensive to our notions of the value of the person." The Court reversed the Superior Court and remanded the case for further proceedings. View "Pennsylvania v. Wisneski" on Justia Law

The issue central to this case was whether Appellee George Banks was competent to be executed. Appellee used a semi-automatic rifle to murder thirteen people and seriously wounded a fourteenth in an early morning shooting spree in 1982. Five of the victims were Appellee's children, and four were Appellee's former or then-current girlfriends. In 2004, the Supreme Court ordered the trial court to determine whether Appellee had the capacity to initiate clemency proceedings or to designate someone to initiate them on his behalf. "To say that [the Court's] direction for expedition went unheeded by [the trial court judge] would be an understatement." Clemency proceedings were delayed by federal counsel seeking to burden the Commonwealth's ability to have its mental health experts examine Appellee in order to prepare a case in rebuttal against counsel's claim that Appellee had become insane. The Court concluded that "the competency question [was] important, but narrow, and it should have been resolved sooner." Following the Court's review of the competency determination rendered by the trial court, the Court concluded that Appellee was incompetent to be executed under the standards set forth in Pennsylvania case law. "It appear[ed] that [Appellee was] in a different place mentally than he was nearly thirty years ago when he committed his crimes and when he was tried." View "Pennsylvania v. Banks" on Justia Law

In 1999, a jury convicted Appellant Steven Hutchinson of first-degree murder and other crimes for the shooting death of one of his girlfriends. Appellant unsuccessfully filed a petition for post-conviction relief raising numerous guilt and penalty phase claims. On appeal to the Supreme Court, Appellant appealed the denial of his guilt phase claims, raising ten issues for the Court’s review. Taking each in turn, the Supreme Court found sufficient evidence in the trial court and PCRA court records to support his conviction. Accordingly, the Court affirmed his conviction. View "Pennsylvania v. Hutchinson" on Justia Law

In 2008, a Pennsylvania Game Commission Officer found Appellant Mark Clegg in possession of two rifles during a hunting incident. Appellant had a prior conviction of attempted burglary. In addition to various summary violations under the Game and Wildlife Code, the Commonwealth charged Appellant with violation of the Uniform Firearms Act. The issue on appeal to the Supreme Court was whether attempted burglary is a "qualifying offense" that prohibits an individual from possessing a firearm under the Act. Upon review of the plain meaning of the Act, the Supreme Court found that attempted burglary is not one of the enumerated offenses under the Act, and as such, was not a "qualifying" offense for which Appellant could be charged in this case. The Supreme Court affirmed the trial court's decision to dismiss Appellant's charge under the Act. View "Pennsylvania v. Clegg" on Justia Law