Justia Pennsylvania Supreme Court Opinion Summaries

In a consolidated appeal, the Commonwealth's Department of Revenue appealed the Commonwealth Court's decisions which held Appellees Northeastern Pennsylvania Imaging Center and Medical Associates of the Lehigh Valley P.C.'s MRI and PET/CT systems were not tangible personal property subject to sales tax under the Tax Reform Code of 1971 because they were part of real estate structures. Finding that the preparation for the installation of the systems and the special way the systems were "annexed" to the buildings in which they were placed, the Commonwealth Court concluded the systems were not tangible personal property subject to the tax but parts to the realty. The Department appealed both decisions. Upon review of the applicable sections of the Tax Code, the Supreme Court found that the equipment was subject to sales tax, and reversed the Commonwealth Court’s decision. View "NE Pa. Imaging Center v. Pennsylvania" on Justia Law

Appellant Abraham Sanchez, Jr. appealed his death sentence, raising eight claims of trial court error regarding aspects of the guilt and penalty phases of his trial, including a challenge to the timing and the use of the jury in adjudicating his claim of death penalty ineligibility under "Atkins v. Virginia," 536 U.S. 304 (2002). Appellant challenged the sufficiency of the evidence presented against him at trial, and sought an acquittal. Upon careful consideration of Appellant's arguments on appeal, the Supreme Court found the evidence was sufficient to convict him and to support they jury's death sentence. The Court found that Appellant was not entitled to an acquittal, and affirmed his conviction. View "Pennsylvania v. Sanchez" on Justia Law

Appellant David Ramtahal appealed his death sentence following his first-degree murder, conspiracy, possession of an instrument of crime and robbery convictions. On appeal to the Supreme Court, Appellant argued that: (1) the evidence was insufficient to convict him of first-degree murder; (2) the verdict was contrary to the weight of the evidence; (3) the trial court abused its discretion in limiting cross-examination of a prosecution witness; and (4) a new penalty hearing is warranted because the jury failed to specify what considerations prompted it to find the mitigating circumstance codified by law. Finding that None of Appellants claims merited relief, the Supreme Court found that Appellant's sentence was supported by sufficient evidence, including the aggravating factors determined by the jury. Accordingly, the Court affirmed Appellant's death sentence. View "Pennsylvania v. Ramtahal" on Justia Law

Appellant Brenda Jones was involved in an automobile accident with another driver that caused damage to her vehicle. Appellant's insurance policy with Nationwide Property and Casualty Company (Nationwide) included collision coverage for the vehicle involved, subject to a $500 deductible. The policy also provided Nationwide with the right of subrogation. Nationwide paid Appellant for all damage to the vehicle, reduced by the $500 deductible. Nationwide then filed a subrogation claim against the other driver and recovered under the other driver's liability coverage. The recovery, while in excess of Appellant's deductible, was only ninety percent of the amount Nationwide paid Appellant under the collision coverage policy. Nationwide paid Jones a pro rata share of the subrogation award by reimbursing her for ninety percent of her deductible, which amounted to $450. Appellant filed a class action against Nationwide claiming that Nationwide's uniform practice of pro rating reimbursements of deductibles violated the "made whole" doctrine. All claims were based upon Appellant's conclusion that Nationwide should have reimbursed her for her entire $500 deductible, despite the provision in the policy granting Nationwide subrogation rights. Appellant also sought injunctive relief to stop Nationwide's practice of pro rata deductible reimbursement. The Supreme Court concluded that the "made whole" doctrine did not apply to the collision coverage at issue in this case, the Court affirmed the dismissal of Appellant's class action. View "Jones v. Nationwide Property & Casualty Ins. Co." on Justia Law

Appellant Kia Motors America, Inc. unsuccessfully defended a class action lawsuit for breach of express warranty. It appealed a superior court's decision to affirm certification of the class by the trial court, and the amount of damages and litigation costs awarded to the class. Costs included a significant legal fee, entered pursuant to the Magnuson-Moss Warranty Improvement Act (MMWA). Appellee Shamell Samuel-Bassett, on behalf of herself and others similarly situated filed this class action lawsuit in January 2001, alleging that her Kia had an unsafe manufacturing defect in the braking system. In 2005, a jury rendered a verdict in favor of the class for breach of express warranty, and awarded damages in the amount of $600 per class member. The court molded the verdict to account for the 9,402 class members to which the parties had stipulated and recorded a $5.6 million verdict. Represented by new counsel, Kia filed an unsuccessful post-trial motion for judgment notwithstanding the verdict, or for a new trial. The issues on appeal to the Supreme Court were: (1) whether the class was properly certified; (2) whether evidence was sufficient to support the jury’s verdict and whether the verdict was against the weight of the evidence; (3) whether the jury’s verdict was properly molded to account for the 9,402 members of the class; (4) whether the trial court had authority to award attorneys’ fees after Bassett entered judgment on the class verdict; and (5) whether the risk multiplier was properly applied to an award of counsel fees under the MMWA. The Supreme Court affirmed in part, and reversed in part, the trial court's decision. The Court reversed the trial court to the extent that its order provided for enhancement of the attorneys' fees award beyond the amount permitted in the MMWA. View "Samuel-Bassett v. Kia Motors America, Inc." on Justia Law

The issue at the heart of this appeal involved whether the superior court interpreted and applied section 385 of the Second Restatement of Torts, which relates to the liability of a contractor or employee who creates a dangerous condition on land on behalf of the land's possessor. Appellee PA Partners, LP sold its steel plant to First Mississippi Steel, Inc. (FMS) in a "turn-key" transaction. FMS employees were operating one of the furnaces when a burn-through and series of steam explosions occurred. During the incident, hot steel fragments and parts of the plant structure fell onto the pouring platform and struck them. One employee was fatally injured and the other survived with scarring and disfigurement. Paula Livingston Gresik (the decedent's widow) and Joseph Beltowski (the injured employee) and his wife sued multiple parties, including PA Partners for damages arising out of the accident. Several years of litigation ensued and the court of common pleas dismissed some of the claims on preliminary objections. Eventually PA Partners remained as the only defendant in the suit. After further pleadings and discovery, the court granted PA Partners' motion for summary judgment on the sole remaining cause of action. The employees appealed to the superior court, maintaining that the court of common pleas failed to recognize that PA Partners could be held liable under a theory of negligent construction described in Section 385 of the Second Restatement of Torts. Upon review, the Supreme Court found that Section 385 did not provide a basis to hold PA Partners liable for damages ensuing from the accident. Accordingly, the Court held that the employees did not demonstrate that the court of common pleas erred in sustaining PA Partners' demurrer. View "Gresik v. PA Partners, LP" on Justia Law

Appellee Raymond Haun was convicted on multiple sexual offenses for which he received a 27 to 97 year sentence in prison. Approximately one year after he was convicted, Appellee sought relief under the PCRA, arguing his trial attorney failed to contest his sentence despite his explicit request for counsel to do so. After testifying to the court regarding his wish to appeal, on cross-examination, the Commonwealth set out to elicit an admission that Appellee had committed the criminal acts for which he was convicted. The PCRA court overruled an objection to the line of questioning. Appellee then responded that he did, in fact, commit the offenses. Furthermore, he acknowledged that he previously admitted his guilt during the presentence investigation, at sentencing and in the assessment process required under Megan's Law. When asked why he wished to appeal his sentence, Appellee responded that he believed the length of his sentence was unfair. The issue before the Supreme Court was whether Appellee's confession of guilt foreclosed his access to judicial review under the Post Conviction Relief Act. The Commonwealth asked the Supreme Court to revisit its holding in "Commonwealth v. Lantzy" (735 A.2d 564 (1999)) and adopt the superior court's decision which "Lantzy" reversed. "In its brief, the Commonwealth has provided [the Court] with nothing to suggest that [the Court] was wrong in Lantzy... [the Court declined] to effectively overrule [its] decision based on a presentation which refuses to come to terms with [its] opinion's governing rationale." The Court held that a concession of guilt did not per se foreclose prisoner access to the PCRA. View "Pennsylvania v. Haun" on Justia Law

Appellant Shawn Walker appealed the dismissal of his motion for a new trial. In 1991, Appellant forcibly entered the home of his former girlfriend, shot and killed a man sleeping on the couch, and shot and permanently disabled the girlfriend. After finding two aggravating factors, the jury convicted Appellant of first degree murder and sentenced him to death. Appellant filed a pro se PCRA petition, raising numerous issues on appeal. Among them, Appellant claimed he received ineffective assistance of counsel because his trial counsel allegedly failed to present specific mitigation evidence. Upon careful review of the trial court and PCRA court records, the Supreme Court concluded that Appellant failed to establish that any of his claims entitled him to a new trial. Accordingly, the Court affirmed Appellant's conviction and sentence. View "Pennsylvania v. Walker" on Justia Law

Defendant Orlando Masionet was charged with the 1982 stabbing death of Jorge Figueroa. A local gang member testified against other members, including Defendant. One member received the death penalty; two others received life sentences. Defendant eluded capture for approximately ten years following the stabbing. Authorities sought help from the television show "America's Most Wanted" to help locate Defendant. He was eventually found in Puerto Rico and extradited to Pennsylvania to stand trial. The Commonwealth's theory of the case was that Mr. Figueroa was killed to prevent him from cooperating with police regarding a robbery-homicide perpetrated two weeks earlier, and Defendant played a part in both the robbery-homicide and death of Mr. Figueroa. Defendant was ultimately convicted of first-degree murder and related offenses. The jury found four aggravating circumstances and no mitigating circumstances for which he was sentenced to death. Defendant argued on appeal to the Supreme Court that the evidence presented at trial was insufficient to support his conviction in both matters. Upon careful review of the trial court record, the Supreme Court found the evidence sufficient to support Defendant's conviction, and affirmed his death sentence. View "Pennsylvania v. Masionet" on Justia Law

In 2006, Developer-Appellee 500 James Hance Court, LP entered into a construction management agreement with Contractor Gorman Construction Company, Inc., pertaining to the erection of a building at 500 James Hance Court, situated within the Oaklands Corporate Center in Exton, Chester County. According to the agreement, the contemplated, 68,000-square-foot structure was to be used as an elementary charter school, and the project was denominated "Collegium Charter School." Soon after the lease and related contracts were executed, the Bureau of Labor Law Compliance notified the School that it was investigating the project to determine whether prevailing wages were required. In this regard, the Bureau explained that charter school construction was treated the same as a traditional school project (re: public works project) for prevailing wage purposes. If the project's phases could be bifurcated, both the school and Appellee would be responsible. The issue between the parties centered on who was ultimately responsible for compliance with the prevailing wage law: the contractor or the school. The Commonwealth Court had found no evidence that the charter school had any role in determining space and performance goals for the project, and therefore the school was responsible for compliance. But upon review, the Supreme Court concluded that the Board’s determination that the lease was a disguised construction contract for the building as a whole, was based on legal error and essential findings which lacked substantial evidentiary support. Facially, the project was rationally divisible according to major phases of shell and fit-out construction. As to the shell, Appellees established the private character of the funding. Furthermore, in terms of economic reality, Appellees presented a prima facie case that Developer's only relationship with the School was per a bona fide pre-development lease. The Bureau failed to go forward with sufficient evidence to the contrary to overcome this prima facie case, and as such, affirmed the Commonwealth Court. View "500 James Hance Ct. v. Pa. Prevailing Wage Appeals Bd." on Justia Law