Justia Pennsylvania Supreme Court Opinion Summaries

The civil action underlying this appeal was selected as a test case for the admissibility of expert opinion evidence to the effect that each and every fiber of inhaled asbestos is a substantial contributing factor to any asbestos-related disease. The inquiry has proceeded under principles derived from 'Frye v. United States' (293 F. 1013 (D.C. Cir. 1923)). Upon its consideration of the evidence presented by both sides, the trial court sustained the Frye challenge and precluded the plaintiffs from adducing the 'any exposure' opinion. Focusing upon methodology, the judge found no support for the any exposure theory of specific causation in any of the sources upon which the expert relied. The Superior Court majority was very critical of the trial court's treatment of the Frye challenge on several fronts. While finding error in the threshold determination, the Superior Court nevertheless proceeded to review the trial court's finding as to general acceptance, concluding that the judge had abused his discretion. At the outset, the Supreme Court concluded the trial court's decision to conduct a Frye hearing concerning the any-exposure opinion to be appropriate. While the Superior Court was correct that the trial court judge did not embellish his opinion with specific citations to the record, his findings and conclusions were 'amply supported throughout that record nonetheless.' The Court concluded that the trial court did not abuse his discretion in its Frye assessment. The order of the Superior Court was reversed, and the case was remanded for consideration of whether there were remaining, preserved issues on appeal which were obviated by the intermediate court's approach to the common pleas court's ruling. View "Betz v. Pneumo Abex LLC" on Justia Law

The Supreme Court granted allocatur in this case to consider the Superior Court's application of the standard of review and to evaluate the relevance of a parent's incarceration to a trial court's decision to terminate a father's parental rights. G.P. (Father), then nineteen, and B.D. (Mother), then approximately seventeen, were involved in an intimate relationship prior to Father's incarceration in December 2004 for the shooting death of his stepfather. While Father was incarcerated, S.P. (Child) was born in May 2005. After Child’s birth, Mother took her to visit Father several times while he was incarcerated at the county prison awaiting trial. In December 2005, Child was declared dependent, when Mother tested positive for THC, a chemical found in marijuana, and was involved in a domestic assault in the presence of Child. Following the declaration of Child’s dependency, Mother and Child apparently moved between several foster homes and Child’s grandmother’s home. In 2007, Child and Youth Services (CYS) filed an emergency shelter petition on behalf of Child when it could not ensure Child's safety. In 2008, Mother voluntarily relinquished her parental rights to Child. At a hearing, testimony was presented that revealed Child suffered from developmental delays and was possibly autistic. A year later at another hearing, CYS moved to terminate Father's parental rights. As applied to this case, the Supreme Court concluded the Superior Court erred in reversing the trial court’s decision to terminate Father’s parental rights: "the trial court did not abuse its discretion when it concluded that “the conditions and causes of the incapacity . . . [could not] or [would] not be remedied” by Father." View "In Re: Adoption of S.P." on Justia Law

Appellant Leroy Thomas (a/k/a John Wayne) appealed an order that denied him post-conviction relief (PCRA). Appellant was convicted by jury of the first degree murder of Kenneth Rankine. At the penalty phase, the jury found one aggravating circumstance: Appellant had been previously convicted of murder. The jury found no mitigating circumstances and sentenced Appellant to death. Appellant filed a direct appeal to the Supreme Court, claiming ineffective assistance of trial counsel and insufficient evidence to support his conviction. The Supreme Court affirmed, finding Appellant failed to establish he received ineffective assistance of counsel, and that the Commonwealth presented sufficient evidence to establish beyond a reasonable doubt he conspired with two others to kill the victim. Appellant then filed a timely pro se PCRA petition, was appointed new counsel, and filed an amended petition. Appellant appealed the denial of his PCRA petition ,raising eight issues. The Supreme Court took each of these issues in turn, and found that Appellant failed to establish the PCRA court abused its discretion in denying Appellant relief. View "Pennsylvania v. Thomas" on Justia Law

Appellant Harve Johnson made a direct appeal to the Supreme Court nunc pro tunc following a jury's imposition of the death sentence for his conviction on first degree murder charges. At the penalty phase, the jury found two aggravating circumstances and one mitigating circumstance. The jury further found the aggravating circumstances outweighted the mitigating circumstance, and sentenced Appellant to death. Appellant raised fourteen issues on appeal, all implicating the admission of certain evidence and sufficiency of the admitted evidence presented at trial. Upon review, the Supreme Court determined the Commonwealth provided sufficient evidence to prove each element of first degree murder. Furthermore, the Court found no abuse of discretion by the trial court in admitting the evidence Appellant complained of at trial. Accordingly, the Court affirmed Appellant's conviction and sentence. View "Pennsylvania v. Johnson" on Justia Law

The Supreme Court allowed this appeal to review a superior court conclusion that a police-citizen encounter ripened into an investigative detention when an officer requested identification from several occupants in a vehicle. In 2007, Appellee John Au was arrested by a Ferguson Township officer and charged with possession of marijuana. Appellee sought the suppression of that evidence. According to the officer’s testimony, it was unusual to see a car in the location at such time, and he decided to make further inquiry. The officer did not activate the emergency lights of his police cruiser, but he positioned his vehicle at an angle relative to the parked automobile so as to illuminate the passenger side. The officer said that he did so without blocking the egress of the vehicle, which he then approached, "probably with a flashlight." The common pleas court awarded suppression of the drug evidence. The court framed the issue as whether the arresting officer had the legal authority to approach the parked vehicle and ask for identification from the occupants when there was no evidence of any criminal activity or a violation of the Motor Vehicle Code. The superior court affirmed. Upon review of the matter, the Supreme Court concluded that the arresting officer’s request for identification did not transform his encounter with Appellee into an unconstitutional investigatory detention. Accordingly, the Court reversed the superior court's order and remanded the case for further proceedings. View "Pennsylvania v. Au" on Justia Law

In this case, the Supreme Court addressed whether there was sufficient probable cause for the issuance of an anticipatory search warrant for Appellant Gregory Wallace's home. After review, the Court concluded conclude there was not and, thus, found the warrant, which authorized a search of Appellant's home after the completion of a controlled purchase by a confidential informant, violated the Fourth Amendment to the United States Constitution, as well as Article I, Section 8 of the Pennsylvania Constitution. The Court therefore reversed the order of the Superior Court and reinstated the order of the trial court which suppressed evidence seized from Appellant's home. View "Pennsylvania v. Wallace" on Justia Law

The issue before the Supreme Court concerned the validity of a single unified tax assessment of both a tract of land, and the buildings of a shopping center, movie theater, and restaurant located on the land. The land was owned by Appellant Tech One Associates, and the buildings and surrounding improvements to the land were constructed and owned by a second entity, "Terra Century Associates" (Lessee). Upon review, Appellees the Board of Property Assessment Appeals and Review of Allegheny County, the Borough of West Mifflin, and the West Mifflin Area School District correctly treated the land, the buildings, and the improvements to the land as real estate subject to taxation under Section 201(a) of the Commonwealth's General County Assessment Law. Further, the Court upheld the rulings of the lower courts that its previous decision in "In re Appeal of Marple Springfield Center, Inc," (607 A.2d 708 (1992)) did not preclude the valuation of real estate owned as a leasehold interest, and that the market value for the land, buildings, and improvements determined at trial accurately reflected the "economic reality" of the impact of the long-term lease between Appellant and its lessee. View "Tech One Assoc. v. Bd. of Prop. Assessment Appeal & Review" on Justia Law

The issue before the Supreme Court concerned whether the Commonwealth could use evidence obtained pursuant to a limited Fifth Amendment waiver in light of a mental health defense used in Defendant Adam Rosen's first trial as rebuttal in his subsequent trial. The issue arose after the superior court upheld Defendant's life sentence for first-degree murder following his retrial. Upon review of the lower courts' record, the Supreme Court affirmed the superior court: "a defendant who raises a mental health defense can be compelled to submit to a psychiatric examination ... in submitting to this examination, however, the defendant does 'not categorically waive his Fifth Amendment [rights].' ...When the defendant voluntarily presents a mental health defense that he subsequently abandons, the Commonwealth may, upon retrial, utilize the results of its psychological examination as to those issues that have been implicated by the defendant's own expert." View "Pennsylvania v. Rosen" on Justia Law

Law enforcement officers suspected that Appellant Calvin Henderson may have co-perpetrated a violent rape-kidnapping. They sought samples of his DNA for comparison with material obtained from the victim and a vehicle used in the commission of the crimes. A member of a police sexual assault unit prepared an affidavit in support of probable cause; secured a magistrate's approval of a search warrant; and collected samples of Appellant's blood, hair, and saliva. The ensuing DNA analysis implicated Appellant, and he was charged. Appellant moved to suppress the evidence on the grounds that the affidavit was insufficient to establish probable cause, contending that the seizures of evidence from his body violated his constitutional rights under the federal and state constitutions. "The motion apparently raised concerns on the prosecution's part," as a decision was made to secure a second warrant. The strategy was to invoke the "independent source doctrine" as applied under the Pennsylvania constitution. Appellant then filed a second suppression motion, asserting that evidence secured under a second warrant was not the product of an independent source. The suppression court denied Appellant's motions. Upon review, the Supreme Court was "unwilling" to enforce a "true independence" rule in the absence of police misconduct "and on pain of the Commonwealth being forever barred from obtaining non-evanescent evidence connecting Appellant with his crimes." The Court concluded that it was appropriate to limit the independent source requirement to situations in which the rule prevents police from exploiting fruits of their own willful misconduct. "Ultimately, [the Court] believe[s] the 'twin aims' of Article I, Section 8 [of the Pennsylvania Constitution] - namely, the safeguarding of privacy and enforcement of the probable-cause requirement - may be vindicated best, and most stably, by taking a more conservative approach to the departure [the] Court has taken from the established Fourth Amendment jurisprudence." View "Pennsylvania v. Henderson" on Justia Law

In May 2009, State Trooper Mark Pizzuti filed a criminal complaint against Defendant-Appellee Jeanette Garcia charging her with tampering with or fabricating physical evidence and simple assault. Presented with "an aberrant procedural history" involving an attempted appeal to the superior court from an order entered by a magisterial district judge following the entry of Defendant's guilty plea, the Supreme Court reviewed the lower courts' record to conclude that the superior court did not have jurisdiction to review the appeal because there was no final order from the court of common pleas. Accordingly, the Supreme Court vacated the superior court's decision and quashed the appeal. View "Pennsylvania v. Garcia" on Justia Law