Justia Pennsylvania Supreme Court Opinion Summaries

In twelve separate matters, Commonwealth citizens, acting singly or in groups, filed appeals from the Final Plan for legislative redistricting of the Commonwealth, which was devised by Appellee 2011 Pennsylvania Legislative Reapportionment Commission (the "LRC"), in response to the U.S. decennial census. Fourteen days after the appeals were filed, seven days after the matters were briefed, and two days after the appeals were argued, the Supreme Court issued its mandate in a per curiam order filed January 25, 2012. That order declared that the Final Plan was contrary to law under Article II, Section 17(d) of the Pennsylvania Constitution, and with the directive in that constitutional provision, the Court remanded the matter to the LRC to reapportion the Commonwealth in a manner consistent with this opinion. View "Holt v. 2011 Legislative Reapportionment Comm'n" 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

Appellees Germantown Cab Company and Sawink, Inc., received fines and suspensions for violations of regulations promulgated by the Philadelphia Parking Authority (the Authority or PPA), pertaining to driver licensure, currency of vehicle inspection, and tire tread wear. The companies pursued declaratory relief and appellate remedies, claiming that the Authority's regulations were invalid, since they were not filed with the Legislative Reference Bureau in accordance with the Commonwealth Documents Law, which is generally applicable to Commonwealth agencies. The Authority took the position that its regulations were proper, though they were not promulgated in accordance with the CDL, in light of the Authority's "unique local focus and consistent with provisions of its enabling legislation." The Commonwealth Court ultimately sustained the appeals, disagreeing with the Authority's arguments that, as "a unique hybrid agency with a local focus," it should be deemed exempt from statutory rulemaking procedures generally applicable to Commonwealth agencies. According to the court, the applicability of the CDL does not turn on an agency's particular focus; rather, it applies to "all agencies, past, present and future, regardless of their mission." Upon review of the applicable legal authorities and the parties' appellate briefs, the Supreme Court agreed with the Commonwealth Court in sustaining Appellees' appeals. View "Germantown Cab Co. v. Philadelphia Parking Authority" 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

The trial court in this case denied Jane Doe's (a minor) application for judicial authorization for an abortion, reasoning, in significant part, that because the minor did not seek parental consent she was not "mature and capable" of giving informed consent independently. The Superior Court affirmed the trial court’s denial of judicial authorization, finding no abuse of discretion. In this appeal, the Supreme Court examined the standard of review applicable to the trial court's denial, and had to determine whether the trial court may, under Pennsylvania law, deny judicial authorization based upon the minor’s failure to obtain parental consent. Upon review of the particular facts of this case, the Supreme Court held that the appeal would be reviewed under the "abuse of discretion" standard. Additionally, the Court held that a trial court lacks statutory authority to deny a minor's petition based on her failure to obtain parental consent. Premised upon these conclusions, the Court vacate the order of the Superior Court, which affirmed the order of the trial court. View "In the Interest of Jane Doe" on Justia Law

The Supreme Court granted review of this case to consider whether a cause of action for negligent infliction of emotional distress (NIED) exists where the emotional distress results from a "negligent breach of a contractual or fiduciary duty," absent physical impact or injury. After review of the development of the tort of NIED under Pennsylvania law and that of other states, the Court concluded that it was appropriate to extend liability for the infliction of emotional distress to a limited "species" of cases. Specifically, the Court suggested that NIED was not available in "garden-variety breach of contractual or fiduciary duty cases," but only in those cases where there exists a special relationship where it is foreseeable that a breach of the relevant duty would result in emotional harm so extreme that a reasonable person should not be expected to endure the resulting distress. The Court further concluded that recovery for NIED claims does not require a physical impact. View "Toney v. Chester Co. Hosp." on Justia Law

In 2001, Appellant Daniel Goodson was involved in a car accident. His insurance company paid $6,300 for the loss to the bank which still held title to the Appellant's car; Appellant received $135. Appellant, dissatisfied with his "meager" share of the insurance proceeds, presented a forged check for $6,300 to his bank with which to open a new account. The bank permitted Appellant to withdraw several thousand dollars before learning that the check was forged. The insurance company confirmed that it had not paid Appellant $6,300. Appellant paid back all the money he had withdrawn, but the State still pressed charges for forgery, insurance fraud and theft. Defendant challenged his sentence and conviction, arguing that he was not guilty of insurance fraud, and that his sentence was accordingly unreasonable. Finding that the trial court erred in convicting Appellant on insurance fraud charges, the Supreme Court remanded the case for resentencing based on forgery and theft. View "Pennsylvania v. Goodson" on Justia Law