Justia Pennsylvania Supreme Court Opinion Summaries

In this appeal by allowance, the issue presented for the Pennsylvania Supreme Court's consideration centered on whether the Commonwealth was permitted to introduce nearly all of a child sexual assault victim’s forensic interview in rebuttal pursuant to Pennsylvania Rule of Evidence 106. In January 2011, Appellant Thomas Raboin began dating K.B. He moved into K.B.’s home shortly thereafter, where she lived with her three minor daughters and multiple other individuals. At this time, K.B.’s eldest daughter (“the victim”) was in kindergarten. Appellant moved out a few years later when the couple ended their relationship, at which point the victim was in second grade. During the victim’s fourth-grade year, she disclosed to her mother that Appellant had sexually abused her while living in their home. K.B. immediately contacted the police, who arranged for a forensic interview. The forensic interview was videotaped and observed by a detective behind a one-way mirror. Appellant was subsequently arrested and charged with: involuntary deviate sexual intercourse with a child, unlawful contact with a minor, indecent assault of a person less than thirteen years of age, endangering the welfare of a child, corruption of minors, and indecent exposure. In 2018, Appellant proceeded to a jury trial. Appellant testified in his own defense at trial, denying the allegations. At the conclusion of Appellant’s presentation of evidence, the Commonwealth requested to play the victim’s forensic interview in rebuttal on the basis that it was a prior consistent statement. Following a lengthy in-chambers discussion involving specific objections to portions of the forensic interview, the trial court largely permitted its introduction, aside from several pages that the court reasoned were hearsay. The trial court’s rationale for allowing introduction of the forensic interview was that it constituted a prior consistent statement and rehabilitative evidence. The Supreme Court concluded that introduction of the interview on this basis was improper, and remanded for the Superior Court to consider, as the trial court initially concluded, whether the interview was nonetheless admissible as a prior consistent statement under Pa.R.A.P.613(c). View "Pennsylvania v. Raboin" on Justia Law

In 2017, Appellant Waylynn Howard (Mother) and her three-year-old daughter (Child) were riding in a car-for-hire which was involved in a three-vehicle accident on a state highway outside of Pittsburgh. At the time of the accident, Mother was sitting in the front passenger seat of the vehicle, and Child was sitting in the back seat, on the passenger side. There was no car seat in the vehicle, and none of the occupants were wearing seatbelts. None of the individuals involved sustained serious injuries. A police officer responded to the scene, and, based on his affidavit of probable cause, Mother was charged with reckless endangerment of another person, and endangering the welfare of a child, a first-degree misdemeanor. At a stipulated bench trial based entirely on the affidavit of probable cause, Mother was convicted of both offenses. The trial court imposed a sentence of one year probation for Mother’s conviction for endangering the welfare of a child, and no further penalty for her conviction for reckless endangerment. Mother appealed, challenging the sufficiency of the evidence to sustain both of her convictions. In an unpublished memorandum opinion, a divided panel of the Superior Court reversed Mother’s conviction for reckless endangerment of another person, finding her actions did not rise to the level of criminal recklessness. However, the panel affirmed Mother’s conviction for endangering the welfare of a child. In this appeal by allowance, the issue presented for the Pennsylvania Supreme Court’s review centered on whether whether evidence that a parent allowed her child to ride in a car-for-hire without being restrained by a child safety seat was, without more, sufficient to support a conviction for endangering the welfare of children under 18 Pa.C.S. 4304(a)(1). The Court concluded that it was not. Accordingly, the Superior Court’s decision was reversed and Appellant’s conviction and judgment of sentence were vacated. View "Pennsylvania v. Howard" on Justia Law

This appeal centered on whether law enforcement agents violated the Sixth Amendment to the United States Constitution when, although issuing Miranda warnings to an arrestee during an interrogation, they failed to specifically apprise him that criminal charges already had been filed against him. In October 2016, Appellant Jordan Rawls and Joseph Coleman perpetrated a home-invasion robbery, during which Kristine Kibler and her son, Shane Wright, were shot and killed. An accomplice, Casey Wilson, served as getaway driver. While shackled, Appellant was interrogated by agents for a period of five-and-one- half hours. At the outset, the lead investigator read Appellant his Miranda rights. He was also specifically admonished that: he was under arrest; he wasn’t free to leave; the agents were investigating the criminal homicides that had appeared in the news; and they had probable cause to obtain a warrant for his arrest. The agents, however, did not specifically advise Appellant that charges already had been lodged against him. During the interrogation, Appellant initially denied knowing Coleman or Wilson and pervasively lied about his whereabouts before, at, and after the time of the home invasion. The agents repeatedly confronted him with contrary evidence. Ultimately, Appellant admitted that he was present at the crime scene when the robbery and homicides were committed, but he professed to having been unarmed, claiming to have served “basically like . . . the lookout.” With regard to the charges filed, Appellant argued that without such information, the waiver of his rights could not be deemed to have been knowing and intelligent. After conducting a hearing, the suppression court found that Appellant had rendered a valid waiver of his right to counsel after receiving appropriate Miranda warnings; the court found nothing to indicate that he was incapable of understanding the rights explained to him and no evidence that the agents threatened, tricked, or cajoled him. Finding no error in the suppression court's judgment, the Pennsylvania Supreme Court affirmed: there was no per se rule invalidating such a waiver merely because an arrestee was not advised that charges had been filed. View "Pennsylvania v. Rawls" on Justia Law

The issue presented to the Pennsylvania Supreme Court in this appeal centered on whether Appellant James Cobbs’ conviction of assault by a life prisoner was vitiated where a court subsequently vacated his predicate sentence of life imprisonment on grounds that it violated the Eighth Amendment to the United States Constitution, and resentenced him on the underlying offense to a term of 40 years to lifetime incarceration. The Supreme Court held that under the circumstances presented, Appellant’s life sentence imposed for his conviction of assault by a life prisoner could not stand. View "Pennsylvania v. Cobbs" on Justia Law

Appellant Gregory Jordan was arrested for his alleged participation in the robbery of Tishana Nowlin. He was charged at docket number 2017-1702 with criminal attempt - homicide, robbery, aggravated assault, criminal conspiracy, persons not to possess a firearm, carrying a firearm without a license, terroristic threats, theft by unlawful taking, and disorderly conduct. At appellant’s request, the persons not to possess a firearm charge was severed and charged at docket number 2018-12031. In fall 2018, at appellant’s request, the parties proceeded to a simultaneous jury and bench trial where the court sat as factfinder for the persons not to possess a firearm charge at 2018-12031 and the disorderly conduct offense at 2017-1702, and the jury served as factfinder for all remaining charges. The issue this case presented for the Pennsylvania Supreme Court's review centered on whether inconsistent verdicts rendered by separate factfinders in a simultaneous jury and bench trial implicated double jeopardy and collateral estoppel concerns, such that a defendant, who was acquitted by the jury on the charges it considered, could not also be found guilty by the trial court of other charges. The Supreme Court concluded that a defendant who elects to proceed with a simultaneous jury and bench trial during a single prosecution is subjected to only one trial and therefore double jeopardy and collateral estoppel do not apply to preclude the guilty verdict rendered by the judge. View "Pennsylvania v. Jordan" on Justia Law

In August 2015, just before 7:00 p.m., a tan 2004 Ford Mercury Grand Marquis occupied by a single male driver travelled at a high rate of speed and struck a moving vehicle occupied by two adults and one child in a residential neighborhood in Northeast Philadelphia. After hitting numerous parked cars, witnesses saw this same vehicle strike a six-year-old child who had been riding her bike and playing on the sidewalk near her home located within the same block. The force of this collision sent the child flying into the air and landing head first in a neighbor’s side garden. The driver was then observed unsuccessfully attempting to escape by driving the vehicle into another parked car, which blocked his exit. The driver was seen immediately thereafter leaping from the driver’s side of the car and running on foot away from the path of destruction he caused. Appellant Mark Edwards was identified as the driver; he was found guilty on all charges, which included one count of aggravated assault, and one count of recklessly endangering another person ("REAP"). Appellant was sentenced to an aggregate term of ten to twenty-five years' imprisonment. Among other things, Appellant argued his sentence for aggravated assault and REAP should have merged if: (1) the two offenses met the elements test set out in 42 Pa.C.C. 9756; and (2) assuming arguendo the elements test was not met, Section 9756 was unconstitutional on its face and as applied, as it conflicted with the Pennsylvania judicial test for merger and violated separation of powers and double jeopardy rights under the Pennsylvania Constitution. Since the Superior Court abided by the language of the statute, it did not, as both Appellant and the Commonwealth suggested, "construe the statute in an overly broad manner to bar merger," the Pennsylvania Supreme Court affirmed the Superior Court’s decision. View "Pennsylvania v. Edwards" on Justia Law

In this matter, the trial court instructed the jury, prior to deliberations, that one of the prerequisites necessary to establish the crime of witness intimidation as a first-degree felony had been fulfilled. The Pennsylvania Supreme Court allowed appeal to consider whether that instruction violated the defendant’s right to a jury trial under the Sixth Amendment to the United States Constitution as interpreted in Apprendi v. New Jersey, 530 U.S. 466 (2000). The Supreme Court found that that the jury found Appellant’s conduct to have encompassed one or more aggravating factors as set forth in paragraph 18 Pa.C.S. 4952(b)(1); the trial court told the jury that, to return a guilty verdict, it would have to find one of the (b)(1) aggravators. That being the case, the verdict, when purged of the taint stemming from the erroneous instruction, established guilt on the witness-intimidation charge at the third-degree-felony level. The maximum prison sentence Appellant would have faced at that level was seven years. Because Appellant was sentenced to twelve years, for Apprendi purposes the sentence was greater than the otherwise-imposable statutory maximum. Judgment was reversed and remanded for further proceedings. View "Pennsylvania v. Dixon" on Justia Law

The victim in this case, Annemarie Fitzpatrick wrote a note in her day planner on the day before she died. The note read: “If something happens to me—JOE,” an apparent reference to her husband, Joseph Fitzpatrick, III. Both the trial court and the Superior Court held that Annemarie’s statement was admissible as an expression of her then-existing state of mind under Rule 803(3). The Pennsylvania Supreme Court concluded the statement was admitted in error, and that the error was not harmless. Hence, judgment was reversed, and the case remanded for a new trial. View "Pennsylvania v. Fitzpatrick III" on Justia Law

In this case of first impression, the Pennsylvania Supreme Court granted allocatur to determine whether Jack Satterfield raised a meritorious challenge to the legality of the sentences imposed on three counts of leaving the scene of an accident involving death or personal injury, stemming from a multi-vehicle crash that resulted in three fatalities. The Supreme Court concluded two of Satterfield’s three sentences were illegal. Accordingly, the Court reversed the order of the Superior Court, vacated the judgment of sentence, and remanded for resentencing. View "Pennsylvania v. Satterfield" on Justia Law

The Pennsylvania Supreme Court granted discretionary review in this case to determine whether the superior court properly determined language in the 2010 amendment to the corruption of minors statute, "in violation of Chapter 31," was an essential element of an offense under the statute. Upon review, the Supreme Court agreed with the superior court's assessment. And, because appellee James Baker-Myers was acquitted of all Chapter 31 sexual offenses charged in the indictment and submitted to the jury, the Supreme Court further agreed that, under these circumstances, appellee's conviction for third-degree felony corruption of minors, could not stand. View "Pennsylvania v. Baker-Myers" on Justia Law