Justia Pennsylvania Supreme Court Opinion Summaries

The Supreme Court granted discretionary review of a superior court order that vacated a sentence imposed on Appellee Shawney Perry who was originally indicted for carrying a firearm without a license. The issue before the Court was whether the superior court misapplied the Supreme Court's directive set forth in "Commonwealth v. Walls," 926 A.2d 957 (2007) concerning the appellate review of sentences. Upon review, the Supreme Court held that the superior court failed to give sufficient deference to the sentencing court's imposition of sentence. Accordingly, the Court vacated the superior court's order and remanded the case back to that court for a reexamination of Appellee's judgment of sentence. View "Pennsylvania v. Perry" on Justia Law

The issue on appeal before the Supreme Court was whether it was possible, as a matter of law, to be convicted as an accomplice to third-degree murder. The Commonwealth presented evidence that the victim was lured to an apartment complex, where he was ambushed, shot, and mortally wounded. Appellant Stanley Roebuck participated with others in orchestrating the events, but he did not shoot the victim. For his role, Appellant was charged with, among other offenses, third degree murder. On appeal, Appellant argued that there is no rational legal theory to support accomplice liability for third-degree murder. The Superior Court affirmed Appellant's sentence. The Supreme Court granted discretionary review, and concluded that a conviction for murder of the third degree is supportable under complicity theory where the Commonwealth proves the accomplice acted with the culpable mental state required of a principal actor, namely, malice. In other words, the Pennsylvania Crimes Code legally, logically, and rationally imposes accomplice liability for depraved heart murder. The Court affirmed the superior court's decision. View "Pennsylvania v. Roebuck" on Justia Law

Appellants Dawn Pyeritz sued the Commonwealth, the Pennsylvania State police and several of its police officers for the destruction of her personal property, speficially "a black nylon tree stand safety harness, or belt, that allegedly was crucial evidence in a separate civil action." The police seized this item during a criminal investigation of a suspicious death. A trooper agreed to retain the belt in the custody of the police, apparently for a longer time than permitted by internal police regulations. The belt was destroyed before Appellants' counsel asked for its return. The trial court granted summary judgment to the Appellees, which the Commonwealth Court affirmed. The Commonwealth Court held that no cause of action exists against a third party – someone other than the original alleged tortfeasor – for negligent spoliation of evidence. The Supreme Court granted review, and now holds that Pennsylvania law does not recognize a cause of action for negligent spoliation of evidence. View "Pyeritz v. Pennsylvania" on Justia Law

The Supreme Court granted review to determine whether a public school district was obligated to fund a kindergarten program offered by a cyber charter school for a four-year-old student when the district exercised its discretion not to offer such a program in its public schools. In 2006, the Secretary of Education notified Appellant Slippery Rock Area School District that funds had been deducted from the district's state subsidy and made payable to Appellee Pennsylvania Cyber Charter School. The Secretary deducted funds because Slippery Rock failed to pay Cyber School for numerous students residing in the district who were attending Cyber School. Slippery Rock objected to the withholding of $1,716.63 for a four-year-old female student enrolled in Cyber School’s kindergarten program. Slippery Rock averred that while it operates a discretionary kindergarten program for five-year-old children, the student at issue did not meet the age requirements for admission into the district’s kindergarten program, Slippery Rock argued that it was not obligated to "assume the costs or obligation of this individual’s enrollment into [Cyber School]." The Secretary concluded that Slippery Rock could not deny payment to Cyber School simply because Slippery Rock did not have a four-year-old kindergarten program. Subsequently the Secretary granted Cyber School's motion to dismiss Slippery Rock's objection. The Commonwealth Court affirmed the Secretary, but the Supreme Court reversed the Commonwealth Court and the Secretary: "[t]o hold that Slippery Rock is obligated to fund educational opportunities for students not yet eligible to attend the district’s public schools would allow those students who enroll in Cyber School to receive greater benefits than a similarly-situated student who chooses to attend the public school." View "Slippery Rock Area Sch. Dist. v. Pa. Cyber Charter Sch." on Justia Law

The issue before the Supreme Court was whether acceptance into an Accelerated Rehabilitative Disposition (ARD) program following a second charge of driving under the influence of alcohol (DUI) constituted a DUI violation and thus triggers the requirement for installation of an ignition interlock system as a condition of restoring a revoked driver's license. In 1998, Appellee John Whalen was convicted of DUI in Florida. Nine years later, Appellee was again arrested for DUI, this time in Pennsylvania. The trial court admitted Appellee into an ARD program after expressly making a determination that Appellee’s 1998 Florida DUI conviction did not present a bar to his entry into this program. Appellee successfully completed his ARD program. Pursuant to one provision of the ARD program, Appellee’s driver’s license was suspended for a period of sixty days, with the added condition that the ignition interlock be installed on his vehicle. Appellee appealed the ignition interlock requirement to the court of common pleas, arguing that the Department had no authority to impose this requirement in his case because ARD was not an adjudication of guilt. The Commonweath Court affirmed the DOT's decision. Upon reivew, the Supreme Court determined that the Commonwealth Court erred in its interpretation of the relevant statutory provisions when it concluded that acceptance into ARD did not establish a DUI violation. Accordingly, the Supreme Court reversed and remanded the case for further proceedings. View "Whalen v. Penna. Dept. of Trans." on Justia Law

Appellant David Chmiel challenged the dismissal of his petition for post conviction relief (pursuant to the Post Conviction Relief Act, 'PCRA'). Appellant was convicted on three counts of first-degree murder in 2002 and sentenced to death. Following his unsuccessful post-sentence motion that asserted forty alleged errors and eight claims of ineffectiveness of trial counsel, Appellant filed a timely pro se PCRA petition. The PCRA court denied Appellant’s request for PCRA relief in a detailed and extensive memorandum opinion and order filed in early 2009. This appeal followed, wherein Appellant stated twelve issues for review. In its own extensive opinion, the Supreme Court found that none of Appellant's assertions had any "arguable merit." The Court affirmed the PCRA court's order dismissing his claims. View "Pennsylvania v. Chmiel" on Justia Law

The Commonwealth appealed a portion of a superior court order that reversed Appellee Daniel Sinnott's conviction for ethnic intimidation baed in insufficient evidence. Appellee got into a heated argument with his landlord/employer, hurling epithets and throwing things at the landlord and members of his family. Appellee was charged with simple assault, terroristic threats, ethnic intimidation, and possession of instruments of crime. He waived his right to a jury, and the trial court convicted him of all offenses, sentencing him to four to 23 months imprisonment for simple assault and a consecutive four years probation for terroristic threats; no further penalty was imposed. Appellee appealed, challenging the sufficiency of the evidence in support of his terroristic threats and ethnic intimidation convictions. The superior court affirmed the terroristic threats conviction, but reversed the conviction for ethnic intimidation, concluding the record failed to establish the landlord's ethnicity was the "primary basis" for appellee's behavior. In crediting appellee's contention that his conduct was solely motivated by anger with the landlord, the Supreme Court found that the superior court not only imposed a non-existing requirement that racial animus be the sole or primary motivator, but also failed to view the evidence of Appellee's repeated derogatory ethnic slurs in the light most favorable to the Commonwealth as the verdict winner. Accordingly, the Supreme Court reversed the portion of the superior court's order reversing appellee's ethnic intimidation conviction, and reinstate the judgment of sentence for that offense. In all other aspects, the order was affirmed. View "Pennsylvania v. Sinnott" on Justia Law

The issue on appeal before the Supreme Court in this case was whether expert testimony is required to convict a defendant of driving under the influence of a drug or combination of drugs when the drugs in question are prescription medications. Appellee Michelle Griffith was charged with DUI following an eyewitness' account of her driving in a "reckless and dangerous manner." Appellee failed field sobriety tests administered by law enforcement. Diazepam, Nordiazepam and "Soma 350" were detected in her blood which Appellee admitted to taking on the morning of the incident. At trial, two individuals testified: the eyewitness and the responding police officer. The trial court convicted Appellee and sentenced her to three months' imprisonment and a fine. Appellee appealed the conviction, arguing the evidence was not sufficient without testimony of an expert to establish the medications impaired her ability to drive safely. The superior court agreed an expert was needed and vacated Appellee's conviction. The Commonwealth appealed. The Supreme Court reversed the superior court, finding the evidence was sufficient to establish Appellee was under the influence of drugs to a degree that impaired her ability to drive. View "Pennsylvania v. Griffith" on Justia Law

In this discretionary appeal, the Supreme Court was asked to address whether the "regular use" exclusion in a personal automobile insurance police was valid to preclude payment of underinsured motorist benefits (UIM) to a police officer injured in the course of employment while operating his police vehicle for which the officer did not have an ability to obtain UIM coverage. Appellant Robert Williams was a Pennsylvania State Trooper seriously injured in an accident involving his police vehicle. At the time of the accident, Appellant maintained a personal automobile insurance policy with Government Employees Insurance Company (GEICO). He sought to recover UIM benefits from GEICO from the accident, but GEICO denied coverage citing the "regular use" exclusion contained in the policy. The trial court granted GEICO's motion to dismiss, and the Superior Court affirmed in an unpublished memorandum. Appellant argued on appeal that because of the special factual circumstances and challenges he faces as a state trooper, his insurer should have provided him with UIM coverage "despite the unambiguous policy exclusion because Pennsylvania has a strong public policy of protecting police officers and other first responders such that they are entitled to special treatment." Upon review, the Supreme Court concluded "Appellant's argument simply fails." The Court held that the trial and superior courts were correct in denying Appellant coverage under his UIM policy, and affirmed their decisions. View "Williams v. Government Employees Ins. Co." on Justia Law

In this capital case, Appellant Ronald Hanible appealed an order of the Court of Common Pleas of Philadelphia County (PCRA court) which denied without a hearing all guilt phase claims raised in his petition for post-conviction relief. Appellant was convicted on two counts of murder. Appellant did not testify on his own behalf or present any witnesses at trial. Instead, he urged the jury to reject the Commonwealth's key witness' testimony as unreliable. Appellant further argued to the jury that none of the physical evidence recovered by police implicated him in the crime. Following the penalty hearing, the jury found two aggravating circumstances and no mitigating circumstances. Accordingly, it returned a verdict of death. Appellant filed a pro se PCRA petition and was appointed counsel. The PCRA court granted a new penalty hearing based on evidence that Appellant's trial counsel failed to present available mitigating evidence. Appellant raised sixteen issues for review to the Supreme Court based on the PCRA's dismissal of his relief petition. The Supreme Court took each in turn, and ultimately affirmed the PCRA court's decision to deny Appellant the relief he requested. View "Pennsylvania v. Hanible" on Justia Law