Justia Pennsylvania Supreme Court Opinion Summaries

On February 6, 2007, following a narcotics investigation and surveillance operation by the Philadelphia police and the FBI, Nasir Far, Regina Little, and Garnell Brown (collectively, "Appellees") were arrested. Appellees were charged with possession with intent to deliver PCP ("PWID-PCP"), possession with intent to deliver marijuana, possession of drug paraphernalia, and conspiracy. Appellees' cases were commenced in the Court of Common Pleas. Although the cases were listed for a preliminary hearing on several dates, the Commonwealth repeatedly failed to produce a chemical laboratory report of the PCP analysis, without which the Commonwealth could not present a prima facie case for PWID-PCP, and thus the cases were continued. In early 2008, Appellees moved for dismissal of the charges against them based on Pa.R.Crim.P. 1013(A)(4), which governs cases that commence in the Court of Common Pleas, but are subsequently transferred to Philadelphia Municipal Court. The Court of Common Pleas conducted a hearing, wherein the Commonwealth countered that Pa.R.Crim.P. 600, the general prompt trial rule applicable to the Court of Common Pleas applied to Appellees' cases. The court did not agree with the Commonwealth, but rather accepted Appellees' contention that Rule 1013(A)(4) controlled the time frame under which the Commonwealth was required to bring Appellees to trial in the Court of Common Pleas under the circumstances of this case. The question therefore, before the Supreme Court was which statute governed the circumstances of this case. The Court determined that the Superior Court incorrectly applied Rule 1013 to the circumstances of this case. Accordingly the Court reversed the Superior Court and remanded the case for further proceedings. View "Pennsylvania v. Far" on Justia Law

Appellant Willie Sneed appealed the denial of his petition for post-conviction relief. Appellant fatally shot Calvin Hawkins in 1980 after discovering that Hawkins and two accomplices sold him aspirin instead of cocaine. A jury convicted Appellant of first-degree murder and possession of an instrument of crime. The jury found two aggravating circumstances and no mitigating circumstances, resulting in the imposition of the death sentence. Appellant timely filed a pro se PCRA petition. It was discovered shortly before Appellant was scheduled to be executed that no one had reviewed his initial PCRA petition. A stay of execution was granted, and in 2000, Appellant with counsel filed an amended PCRA petition raising twenty-five claims of error. Upon review, the Supreme Court rejected Appellant's allegations of error for "lack of arguable merit." The case was remanded to the PCRA court to conduct a new penalty phase hearing based on the Court's prior decision stemming from Appellant's pro se petition. View "Pennsylvania v. Sneed" on Justia Law

In a matter of first impression, the Supreme Court was asked to decide whether the Commonwealth's waiver of application of the school zone mandatory minimum sentence at the original sentencing precluded the Commonwealth from subsequently seeking its application following the revocation of probation. In 2008, two men broke into Appellee Robert Mazzetti's apartment and stole marijuana and other items. At the time of the incident, Appellee was a college student residing in an off-campus apartment. Police would later arrest Appellee and charge him with possession with the intent to deliver the stolen marijuana. Pursuant to an agreement, Appellee pled guilty in exchange for an agreed upon sentence of twelve months of probation; the Commonwealth agreed not to prosecute the other charges. At the time of the plea, the Commonwealth agreed to waive the mandatory minimum sentence applicable to possession in a school zone. Appellee later violated the terms of his probation when he attempted to steal two jars of honey from a grocery store. The Commonwealth moved to revoke Appellee's probation, and provided notice of its intent to seek the school zone mandatory minimum for the possession conviction. The trial court deferred resentencing to allow the parties to brief the issue of whether the Commonwealth could ask the court to impose the school zone mandatory minimum at resentencing following the probation revocation. The trial court eventually ruled that it was not required to impose the mandatory minimum sentence, and the Superior Court affirmed. Upon review, the Supreme Court concluded that the statutory scheme governing the mandatory minimum precluded the Commonwealth from requesting imposition of the mandatory minimum at resentencing when it waived its initial applicability. View "Pennsylvania v. Mazzetti" on Justia Law

At issue in this direct appeal to the Supreme Court was a statutory prerequisite to the obligation of the Insurance Department to defend certain medical professional liability actions asserted against health care providers, and to the requirement for payment of claims asserted in such actions from the Medical Care Availability and Reduction of Error Fund. Specifically, resolution of the appeal turned on when, under the governing statute, a "claim" is "made" outside a specified four-year time period. On June 4, 2007, Joanna Ziv filed a praecipe for a writ of summons naming Appellant Phillip Yussen, M.D. and other medical providers as defendants. A complaint was filed on August 2, 2007, alleging medical negligence last occurring on July 7, 2003. Appellant’s primary insurer, Pennsylvania Healthcare Providers Insurance Exchange, requested that the claim be accorded Section 715 status by the Insurance Department. The Department denied such request, however, on the basis that the claim had been made less than four years after the alleged malpractice. Appellant initially challenged this determination in the administrative setting, and a hearing ensued. Before the examiner, Appellant argued that, consistent with the policy definition of a "claim," the date on which a claim is made for purposes of Section 715 cannot precede the date on which notice is provided to the insured. Appellee, on the other hand, contended that a claim is made when it is first asserted, instituted, or comes into existence - including upon the tender of a demand or the commencement of a legal action - and that notice to the insured or insurer is not a necessary prerequisite. In this regard, Appellee Medical Care Availability & Reduction of Error Fund highlighted that Section 715 does require "notice" of the claim to trigger the provider's obligation to report the claim to the Fund within 180 days, but the statute does not contain such an express notice component in delineating the four-year requirement. The Commonwealth Court sustained exceptions to the hearing examiner's recommendation lodged by Appellee and entered judgment in its favor. In its review, the Supreme Court found "claim" and "made" as used in Section 715 ambiguous. The Court determined that for purposes of Section 715, the mere filing of a praecipe for a writ of summons does not suffice to make a claim, at least in absence of some notice or demand communicated to those from whom damages are sought. The Court remanded the case for entry of judgment in Appellant's favor. View "Yussen v. Med. Care Availability & Reduction of Error Fund" on Justia Law

In 1985, the Board of Commissioners of Lackawanna County formed the Multi-Purpose Stadium Authority of Lackawanna County. The Stadium Authority subsequently acquired a minor league baseball team, now the "SWB Yankees." Capital was raised via bonds and other public financing, the Authority constructed the Lackawanna County Stadium, now known as PNC Field to serve as the home field for the franchise. From 1989 to 2006, the Authority managed all projects at the Stadium, including the day-to-day operations of the team. The Authority eventually consummated a management agreement with Mandalay Baseball Properties, LLC, a private entity, which vested Mandalay with the overall management and control of the day-to-day operations of the baseball club and the Stadium. Under the contract, Appellant SWB Yankees, LLC became the sole and exclusive manager of all baseball operations and other entertainment activities and events conducted at the Stadium. Gretchen Wintermantel, a reporter for the Scranton Times Tribune (collectively “Appellees”), submitted a request to the Stadium Authority seeking “access to and copies of all names and the bids submitted to [Appellant] for a concessionaire contract at [the Stadium].” Appellees invoked the Right-to-Know Law, which generally provides for access to “public records,” of a Commonwealth or local agency. The Stadium Authority’s solicitor denied the request, stating that the Authority did not possess such information, and that it was not performing a governmental function on behalf of the Stadium Authority. Appellees appealed to the Office of Open Records, taking the position that any action by Appellant as the Stadium Authority’s agent is public business. In its opinion, the court of common pleas initially rejected Appellant’s argument that the bids for a concessionaire contract were not “records” for purposes of the Right-to-Know Law, since Appellees’ request was phrased broadly such that it might be read as subsuming intangible information. After Appellant lodged an appeal, the Commonwealth Court issued its decision in "East Stroudsburg University Foundation v. OOR," (995 A.2d 496 (Pa. Cmwlth. 2010)) determining that “all contracts that governmental entities enter into with private contractors necessarily carry out a ‘governmental function’ [for purposes of Section 506(d)(1)] --because the government always acts as the government.” Having reviewed the relevant statutory scheme, the parties’ arguments, and the record, the Supreme Court agreed with the appeals officer, the court of common pleas, and the Commonwealth Court that the disclosure of any written concessionaire bids is required per Section 506(d)(1) of the Right-to-Know Law. View "SWB Yankees, LLC v. Wintermantel" on Justia Law

The issue before the Supreme Court in this case centered on whether Appellant Six L's Packing Company and its claims administrator Broadspire Services, Inc. bore liability for workers' compensation benefits as a statutory employer of an injured truck driver employed as an independent contractor. Appellant owns and leases various farms and distribution and processing facilities in North America. Claimant suffered injuries in a vehicle accident on a Pennsylvania roadway while transporting Appellant’s tomatoes between a warehouse in Pennsylvania and a processing facility in Maryland. Appellant submitted evidence to establish that it did not own trucks or employ drivers, but, rather, utilized independent contractors to supply transportation services. Appellant thus took the position that it was not Claimant’s employer. The WCJ found Appellant liable for payment of workers' compensation benefits. On further appeal, the Commonwealth Court affirmed on essentially the same reasoning as that of the WCJ. In its review, the Supreme Court affirmed the Commonwealth Court, recognizing "a degree of ambiguity inherent in the overall scheme for statutory employer liability, arising out of differences in the definitions for “contractor” as used in various provisions of the Workers' Compensation Act (WCA); the idiosyncratic conception of subcontracting fashioned in Section 302(a) [of the Act]; the substantial overlap between Sections 302(a) and (b); and the apparent differences in the depiction of the concept of statutory employment as between the Act’s liability and immunity provisions. Viewing the statutory scheme as a whole, however, and employing the principle of liberal construction in furtherance of the Act’s remedial purposes, [the Court found] it to be plain enough that the Legislature meant to require persons (including entities) contracting with others to perform work which is a regular or recurrent part of their businesses to assure that the employees of those others are covered by workers’ compensation insurance, on pain of assuming secondary liability for benefits payment upon a default." View "Six L's Packing Co. v. WCAB" on Justia Law

The issue before the Supreme Court was the proper method of calculating an hourly-wage claimant's average weekly wage under Section 309 of the Workers’ Compensation Act where the specific loss claimant suffered an initial incident, changed employers, and later suffered a work-related injury caused by the initial incident. Claimant Janice Weber-Brown worked for Appellant Lancaster General Hospital as a licensed practical nurse. In 1980, while cleaning the tracheotomy of a patient who was infected with the herpes simplex virus (HSV), the patient coughed, causing sputum to spray in Claimant’s left eye. Approximately two weeks after the incident, Claimant’s eye became swollen and infected, and Claimant believed she contracted HSV. Claimant left the employ of Lancaster General in 1985 for reasons unrelated to the eye incident. At that time, she earned $8 per hour and worked full-time. In the years following her departure from the hospital, Claimant’s eye became infected several more times. Each time, her symptoms subsided with treatment, and Claimant did not miss any work with her other employers due to her eye infections. In October 2006, however, Claimant’s eye again became infected and, this time, her infection did not respond to treatment. By February 2007, Claimant lost the vision in her left eye, and, in May 2007, she underwent a cornea transplant. The transplant did not improve her vision, and, as a result of her blindness, she was not able to return to work. At that time, Claimant earned $21 per hour. Lancaster General denied Claimant's allegations that she contracted HSV while working for the hospital, and challenged her claim that she be paid based on her then-current wage with her new employer. The WCJ determined Claimant suffered a work-related injury and held that the hospital pay Claimant's wage set at $21 per hour. Lancaster General appealed. Upon review, the Supreme Court concluded that the WCJ correctly held that the Claimant's weekly wage should have been based on her 2007 wages with her new employer, as those wages were earned with that employer at the time Claimant suffered her work-related injury. View "Lancaster Gen. Hospital v. WCAB" on Justia Law

The Commonwealth asks the Supreme Court to consider whether the materiality requirement of "Brady v. Maryland" (373 U.S. 83 (1963)), is satisfied where the evidence not disclosed by the Commonwealth and would itself not have been admissible at trial. The Commonwealth further requested the Court reconsider, based on more recent decisions by the Pennsylvania Court and the United States Supreme Court, the Court's holding in "Commonwealth v. Green," (640 A.2d 1242 (1994)). After careful consideration, the Pennsylvania Supreme Court held that nondisclosed favorable evidence which is inadmissible at trial may be considered material for purposes of "Brady," as long as there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different. "Mere speculation by a defendant . . . will not be sufficient to meet this standard; rather, he must identify specific evidence or information that would have been uncovered, and explain how that evidence or information would have changed the result of the proceeding." Notwithstanding its holding, because the Court found in this case that Appellee did not establish there was a reasonable probability that, had the evidence withheld by the Commonwealth been disclosed, there would have been a different outcome at trial, the Court reversed the order of the Superior Court remanding for a new trial, and reinstated Appellee's judgment of sentence. View "Pennsylvania v. Willis" on Justia Law

The Supreme Court granted review in this case to determine whether the courts below erred in dismissing criminal charges against Defendant-Appellee David Bradford. The trial court discontinued the case because the Commonwealth failed to bring Defendant to trial within the time required by Pennsylvania's speedy trial rule (Pa.R.Crim.P. 600) when the Magisterial District Judge failed to forward timely the relevant file as required by Pa.R.Crim.P. 547(B). Upon review, the Court determined that dismissal was not appropriate under Rule 600 when the Commonwealth acted with due diligence in relying upon the judicial system to transfer documents in accordance with the Rules of Criminal Procedure. Accordingly, the Court reversed the dismissal of charges and remanded the case to the trial court. View "Pennsylvania v. Bradford" on Justia Law

Appellant Alexander Keaton appealed the denial of his application for post-conviction relief; the Commonwealth cross-appealed the grant of a new penalty phase based on trial counsel's ineffectiveness for failing to present mitigating mental health evidence. In 1992, Appellant was charged with rape and related offenses stemming from the sexual assault of Nadine S. One month later, the body of Appellant's ex-girlfriend was found. After waiving his rights, Appellant gave a written statement incriminating himself in the killing, and he was charged with murder. Appellant sexually assaulted two other women, making self-incriminating statements. The Commonwealth moved to consolidate the charges for all victims. Over defense objection, the trial court granted the motion. Prior to trial, Appellant moved to suppress his statements; the motion was denied, and Appellant was tried before a jury and found guilty of first degree murder, rape, and related offenses. At the penalty phase, the Commonwealth sought to prove several aggravating circumstances. The jury found no mitigating circumstances and one aggravating circumstance. Accordingly, Appellant was sentenced to death. Appellant timely filed a pro se PCRA petition and received appointed counsel, who filed an amended petition alleging all prior counsel's ineffectiveness for not raising numerous guilt and penalty phase issues. The PCRA court held a hearing on the sole issue of trial counsel's ineffectiveness for failing to investigate and present mitigating evidence at the penalty phase. The PCRA court rejected Appellant's guilt phase claims, and denied him a new trial. However, the court concluded trial counsel was ineffective for failing to develop and present mitigating evidence, and granted a new penalty hearing. The PCRA court's opinion did not address several of the issues in detail, it merely stated it found Appellant's claims of guilt phase error meritless and would not further discuss them; the only penalty phase issue the court addressed was trial counsel's ineffectiveness. Without conclusive findings regarding whether Appellant was mentally retarded, the Supreme Court could not address his "Atkins" claim; accordingly, the Court remanded for the PCRA court to consider that claim's merits. The PCRA court complied, and rejected Appellant's claim of mental retardation. On appeal of that decision, the Supreme Court determined that there was a factual question regarding whether Appellant invoked his Fifth Amendment right to counsel in 1992 when he made his self-incriminating statements. The Court remanded this issue to the PCRA court for determination of this issue and for the parties to address the applicability of the applicable case law if the court determined Appellant did invoke his right. As to Appellant's remaining guilt phase claims, the Supreme Court affirmed the PCRA court's denial of relief. View "Pennsylvania v. Keaton" on Justia Law