Justia Pennsylvania Supreme Court Opinion Summaries

Following a bench trial in October 2001, Appellee Jules Jette was found guilty of involuntary deviate sexual intercourse, endangering the welfare of a child and corruption of minors charges. Appellee was sentenced to ten to twenty years' imprisonment, with consecutive terms of probation for seven and five years. The post-conviction-relief court (PCRA) found no merit to Appellee's claims for relief. Appellee's counsel strategically chose not to challenge all issues addressed by the PCRA court in its opinion that dismissed the case. Appellee appeared pro se to appeal to the Superior Court. The Superior Court found that Appellee was entitled to new counsel and remanded the case back to the PCRA court. The Commonwealth appealed the Superior Court's order to the Supreme Court. After a careful review of the Superior Court's opinion, the applicable law and the briefs of the parties, the Supreme Court found that the Superior Court misread the applicable legal standard which was the basis of its opinion. As a result, the Commonwealth found itself in the "unusual position" of advocating in defense of the "honor, independence and professionalism of the criminal defense bar" in its appeal of the Superior Court's order. The Supreme Court vacated the Superior Court's order and remanded the case back to the PCRA for further proceedings. View "Pennsylvania v. Jette" on Justia Law

The State Ethics Commission (Commission) appealed from an order of the Commonwealth Court that reversed the Commission's findings that Appellee Kenneth Kistler had violated two provisions of the Public Official and Employee Ethics Act (Act). Appellee was a member of the Carbon-Lehigh Intermediate Unit's (CLIU) board of directors from 1998 to 2002. As chairman of the building committee, Appellee was charged with pursuing the board's interests in various construction projects. Appellee also owned two building supply businesses. In late 1999, the board explored the possibility of constructing a garage in which to house its buses. The project's architect contacted Appellee as possible supplier for the project. Subsequently, Appellee resigned from his position with CLIU as a possible conflict-of-interest. At a board meeting, the solicitor for the CLIU opined that Appellee could "properly participate" in construction of the garage, but that he should abstain from any votes relating to that project. More projects were planned, and Appellee's businesses were again considered as suppliers. By this time, Appellee had withdrawn completely from participation with the CLIU's building committee. In 2004, the Commission notified Appellee that he was being investigated for possible violations of the Ethics Act. The Commission thereafter concluded that Appellee unintentionally violated the Act three times. The Commonwealth Court reversed the Commission’s decision. In its interpretation of the Ethics Act, the court found no evidence that Appellee's participation in the building committee's discussions lead to the committee's choosing his private businesses for its building projects. Upon review, the Supreme Court concluded that the Commonwealth Court correctly interpreted the Ethics Act and affirmed its decision. View "Kistler v. State Ethics Comm'n" on Justia Law

In 2005, Robert Sample was found face down on a Philadelphia city sidewalk, dead from multiple gunshot wounds to his head and neck. In canvassing the area for witnesses, detectives knocked on the door of a third-floor apartment in a nearby high-rise. Jamilla and Dominique Everett opened the door. After obtaining permission to enter the apartment, detectives found Jamilla's children, Dominique's boyfriend Khalif Alston and Appellee Ernest Cannon asleep inside. Everyone inside the apartment denied any knowledge of the shooting but agreed to accompany the police to the station for further questioning. Later on the day of the murder, the Everetts consented to a search of their apartment. Police recovered a semiautomatic handgun from inside the toilet tank. Everyone inside the apartment that day was questioned again. When detectives interviewed Mr. Alston, he confessed to his role in the crime and implicated Appellee. Following the consolidation of their cases, a jury tried both men. Since Appellee and Mr. Alston were being tried together, the statement that Mr. Alston gave to the police on the day of the murder was redacted by substituting the phrase "the other guy" for any reference to Appellee by name. The prosecution "slipped" and named Appellee in his opening statement as he recounted the events on the date of the murder. At the conclusion of the prosecutor's opening, Appellee objected and moved for a mistrial, claiming that the prosecutor "broke the redaction." The trial court gave the jury an immediate cautionary instruction. The jury returned a verdict against Appellee, convicting him of first-degree murder, robbery, conspiracy and carrying a firearm. The trial court then sentenced Appellee to life in prison for the murder conviction, with concurrent sentences for the other charges. On appeal to the Superior Court, Appellee successfully argued that he was entitled to a new trial because of the prosecutor's slip up during his opening statement. The Commonwealth appealed, arguing that the trial judge's cautionary instruction was sufficient to support Appellee's conviction. Upon review, the Supreme Court found that the trial court gave "direct, unequivocal and strong" cautionary instructions, repeatedly detailing the proper manner of weighing the evidence. "The trial court, which is in the best position to assess whether any prejudice can be cured, determined that the prosecutor's comment did not justify a mistrial." Accordingly, the Court reversed the judgment of the Superior Court and reinstated the verdict and sentences of the trial court. View "Pennsylvania. v. Cannon" on Justia Law

In this appeal, the Supreme Court consolidated four cases to decide whether adopted children whose adoptions were procured through a state-licensed private agency in the 1990s were eligible to receive adoption assistance subsidies retroactive to the dates of the children’s adoptions and prospectively through their eighteenth birthdays. The children’s attorneys successfully argued to the Commonwealth Court that the adopted children were eligible for subsidies pursuant to the Pennsylvania Adoption Opportunities Act (AOA). The Department of Public Welfare (DPW) appealed the Commonwealth Court’s decision. Upon review of the underlying cases, the Supreme Court held that "adoption subsidies were never intended to be windfalls for adoptive parents." The Court reversed the lower court’s decision and reinstated the DPW's ruling with respect to the appellants in the consolidated cases. View "Laird v. Penna. Dep't. of Public Welfare" on Justia Law

Appellant Robert Petty is sole owner of Co-Appellant R.G. Petty Masonry. Appellants contracted with Respondent Blue Cross of Northeastern Pennsylvania (Blue Cross), a nonprofit hospital corporation that provides health insurance coverage for its employees. Appellants are covered under the group policy as subscribers. Appellants filed a four-count class action suit against Blue Cross, alleging that it violated the state Nonprofit Law by accumulating excessive profits and surplus well beyond the "incidental profit" permitted by statute. The second count alleged Blue Cross breached its contract with Appellants by violating the Nonprofit Law. The third count alleged Blue Cross owed appellants a fiduciary duty by virtue of their status as subscribers, and that duty was breached when it accrued the excess surplus. The fourth count requested an inspection of Blue Cross' business records. The trial court found Appellants lacked standing to challenge Blue Cross' alleged violations of the Nonprofit Law and dismissed the suit. The Commonwealth Court affirmed the trial court. Upon careful consideration of the briefs submitted by the parties in addition to the applicable legal authorities, the Supreme Court found that Appellants indeed lacked standing under the Nonprofit Law to challenge Blue Cross by their four-count complaint. Accordingly, the Court affirmed the lower courts' decisions and dismissed Appellants' case. View "Petty v. Hospital Service Assoc. of NE Penna." on Justia Law

Defendant Ralph Birdsong unsuccessfully appealed his sentence for murder, rape and assault. He was sentenced to death. In his appeal to the Supreme Court, he argued that the appellate court improperly denied his petition for post conviction relief. Defendant cited multiple errors at trial that entitled him to a reduction in his sentence or complete dismissal of the charges against him. The Supreme Court reviewed the record and found that Defendant was not entitled to relief. The Court affirmed the order of the lower courts denying Defendant's petition for post conviction relief.

The State appealed a Superior Court order that allowed Defendant Vincent Moto to expunge his criminal record. In 1987, Defendant was convicted of rape, deviate intercourse and conspiracy charges and was sentenced to a maximum twenty-four year sentence. Ten years into his sentence, DNA testing exonerated the Defendant. The State "nolle prossed" his case. In 2007, Defendant petitioned the court to expunge all records of his arrest, trial, conviction and sentence. The attorney who originally prosecuted the case opined that the DNA evidence did not necessarily exculpate Defendant because he was still present at the scene. Furthermore, the State would have retried Defendant except that the victim had moved out of state. The trial court ultimately denied Defendant's request to expunge his record. Upon review, the Supreme Court concluded that it was unable to agree with neither Defendant's assertions nor the Superior Court's determinations of trial court error. The trial court denied Defendant's petition to expunge based primarily on the strength of the original 1987 case against him, and the inability of DNA evidence to exonerate him. The Court therefore reversed the Superior Court, and reinstated the trial court's decision.

The Commonwealth Court declined to issue a writ of mandamus to Appellant Crozer Chester Medical Center (Crozer) in its attempt to force the Department of Labor and Industry (Department) to reimburse it for medical fees. Claimant William Radel suffered a work-related injury while lifting a bundle of rebar for his employer. The claimant underwent surgery at Crozer, and Crozer sent claimant's records and the bill to claimant's insurance company, Zurich North American Insurance (Zurich). Zurich did not pay, nor did it deny the claim. Crozer then turned to the State for reimbursement. The Department rejected the application as "premature," because Zurich's non-payment made an "outstanding issue of liability/compensability for the alleged injury." Crozer then petitioned the Commonwealth Court to force the Department to pay. The Supreme Court agreed that Crozer's application for reimbursement was premature. The Court found that Crozer did not try to resolve Zurich's nonpayment before petitioning the State or the Commonwealth Court. The Court affirmed the decision of the Department and the lower court, and dismissed Crozer's petition for a writ of mandamus.

Pennsylvania's current version of Megan's Law requires individuals convicted of kidnapping, indecent assault, or promoting prostitution to register for ten years following release from jail or probation. Persons convicted of two or more offenses subject to the ten-year registration must register for life. Allegheny County (the County) amended its code to add to the registration requirements: if a registrant moves to a "prohibited area" within the County, s/he will have 45 days to move out. Failure to move within the 45 days would constitute a separate offense. Appellee Charles Fross and several other parties were convicted sex offenders subjected to the County's new rule. They brought suit in federal court to challenge the new ordinance, arguing that the rule was preempted by the state Sentencing and Parole Codes, and asked the court to declare the ordinance invalid. The federal court certified the question of whether the County's ordinance was preempted by the Pennsylvania Prisons and Parole Code and/or by the Pennsylvania Sentencing Code to the Supreme Court. The County argued that the ordinance was a permissible exercise of its powers, and was valid. The Supreme Court found that the ordinance "impedes the accomplishments of the full objectives of the General Assembly, as expressed in the Sentencing and Parole Codes, and is . . . invalid pursuant to our conflict preemption doctrine."

Appellant Walnut Street Associates (WSA) provides insurance brokerage services and helps employers obtain health insurance for their employees. Appellee Brokerage Concepts, Inc. (BCI) is a third party administrator of employee benefit plans. Procacci retained BCI as administrator of its insurance plans, and BCI paid commissions to WSA based on premiums paid by Procacci. In 2005, Procacci requested BCI reduce its costs, but BCI would not meet Procacciâs proposal. Procacci then notified BCI that it would take its business elsewhere. BCI asked Procacci to reconsider, and in the process, disclosed to Procacci how much it paid to WSA as its broker. The amount was higher than Procacci believed WSA had been earning, but there was no dispute that BCIâs statements about WSAâs compensation were true. As a result of BCIâs letter, Procacci terminated its contract with WSA. WSA sued BCI alleging that BCI tortiously interfered with the WSA/Procacci contract by disclosing the amount of WSAâs compensation. BCI argued that it could not be liable for tortious interference because what it said was true, or otherwise justified and privileged. At trial, the jury found that BCI did interfere in the WSA/Procacci contract. BCI appealed, and the appellate court reversed the trial courtâs judgment. The appellate court adopted a section of the Restatement of Torts, which said that truth is a defense to a claim of tortious interference. WSA maintained that the Restatement was not applicable according to Pennsylvania law. The Supreme Court reviewed the case and adopted the Restatement defense that truth is a defense to claims of tortious interference with contractual relations. The Court affirmed the decision of the appellate court.