Justia Pennsylvania Supreme Court Opinion Summaries

Appellee Ronald Gibson challenged his sentence for the shooting deaths of a police officer and a bystander during a failed robbery attempt at a bar in Philadelphia. After multiple remands, Appellee argued to the Supreme Court that he received ineffective assistance of counsel that resulted in prejudice against him at trial. The appellate court concluded that Appelleeâs counsel was âderelictâ by failing to adequately investigate life-history or mental health mitigation evidence. The court concluded, however, that the trial court should have resolved certain questions that arose from evidentiary discrepancies. The Supreme Court performed an exhaustive review of the evidence presented at trial. While not diminishing Appelleeâs troubles, the Court found that the mitigating evidence Appellee sought to enter at trial was not enough to overcome the aggravating factors introduced at trial or to overturn the juryâs verdict. The Court held that Appelleeâs claim for ineffective assistance of counsel to be unfounded, and it affirmed Appelleeâs conviction and sentence.

Appellee Edward Watts was convicted of first-degree murder and numerous other offenses in 2001 and sentenced to life imprisonment. He filed a timely direct appeal, but the Superior Court dismissed it for failing to include a docketing statement. Defense counsel was directed to certify that he had notified Appellee of the dismissal, but he never filed the required certification saying that he did so. Throughout 2002 and 2003, Appellee sought status updates on his appeal. In August, 2003, the Superior Court advised Appellee that his appeal had been dismissed. Within days of receiving that notice, Appellee filed a pro se Post Conviction Relief Act (PCRA) petition, seeking reinstatement of his appellate rights. The PCRA Court dismissed his claim, but the Superior Court reversed that decision. The Supreme Court was not persuaded by Appelleeâs argument that because he did not know (and had no way of knowing except through his attorney) that the appeal had been dismissed, he should be afforded an opportunity to have his petition heard. The Court reversed the Superior Courtâs decision, finding Appelleeâs petition was properly dismissed in the lower court for being untimely filed.

Appellant Mark Spotz appealed the denial of his petition for collateral relief under the Commonwealthâs Post Conviction Relief Act (PCRA). While engaged in a three-day crime spree in early 1995, Appellant killed four people in four counties. He was tried separately for each homicide, and he was ultimately convicted of first-degree murder and given the death sentence. Since his conviction, Appellant has applied for and received judicial review of his convictions and sentence. Each time, Appellant has raised constitutional bases or trial and/or appellate court errors to seek the next review. The string of appeals ends for now with this case. Here, Appellant sought review of an order of the PCRA court that denied his petition for collateral relief relating to the death of Betty Amstutz in February, 1995. During the guilt phase of trial, Appellant appeared pro se and asserted an innocence defense. The jury found him guilty. He was assigned a public defender for the sentencing phase and was sentenced to death. Appellant appealed to the PCRA alleging errors at trial, ineffective assistance of counsel, and a host of other matters, all of which were denied. The Supreme Court engaged in an exhaustive review of Appellantâs case history dating back to the original trial in 1996, and found no errors that warranted the post-conviction relief Appellant sought. The Court affirmed the lower courtsâ decisions.

Appellant, the Pennsylvania State Troopers Association, appeals a portion of the opinion and order issued by the Commonwealth Court that invalidated a provision of âAct 111â that addressed the pay state troopers are to receive while on âunion leave.â A collective bargaining agreement (CBA) was set to expire in 2008. When the parties reached an impasse in their negotiations for a new CBA, the Association requested arbitration pursuant to Act 111. After a hearing, the Act 111 Panel entered an award concerning several issues, including the issue of payment to troopers while on âunion leave.â The Commonwealth appealed the arbitration award to the Commonwealth Court. The Court vacated the union leave provision of the award. On appeal to the Supreme Court, the Commonwealth argued that the union leave provision of the award violated the State Employeesâ Retirement Code (SERC). The Supreme Court held that the union leave provision did not violate SERC, and that arbitration award was within the authority of the arbitration panel to award. Because arbitration awards issued pursuant to Act 111 are final and binding on the parties with no appeal permitted to any court, the Supreme Court reversed the Commonwealth Courtâs decision to the extent it contradicted the holding of this case.

In 1998, Appellee Stephen Heim filed a professional liability action against two doctors and their medical practices alleging that their negligent care from 1992 to 1996 caused the death of his wife. In August 2000, Mr. Heim received a jury verdict for over $1 million. The jury attributed a substantial percentage of fault to Mrs. Heim, and apportioned the remaining liability among the defendant doctors, which they bore jointly and severally. At the time of the alleged negligent acts, the doctors each maintained primary professional liability insurance coverage for $200,000 per occurrence under a policy issued by a private insurer. That insurer went bankrupt, and the policy was assumed by the Pennsylvania Property and Casualty Association (PPCIGA). Excess liability protection was provided to health care providers through a government-run contingency fund known as the Medical Professional Liability Catastrophe Loss Fund (CAT Fund). It was determined that the primary insurance policy left a $100,000 shortfall in order to satisfy Mr. Heimâs judgment. The CAT Fund determined it had no responsibility to redress the shortfall from the primary insurerâs bankruptcy. With no insurance money to protect them, Mr. Heim sued against the doctorsâ assets seeking to recover the unpaid portion of the judgment that neither the insurance company nor the CAT Fund would pay. The Commonwealth Court ruled in Mr. Heimâs favor, but in accordance with joint and several liability, applied the order to both PPCIGA and the CAT Fund. The Fund appealed to the Supreme Court. The Supreme Court found that under the statutory scheme that governs the CAT Fund, the facts of this case clearly implicated the Fundâs responsibility to the doctors to pay for the $100,000 shortfall left by their primary insurance policy. Accordingly, the Court affirmed the decision of the Commonwealth Court.

L.J.B. was born to C.L.F. (Mother) and S.M.B. (Father) in August, 2001. The parents had been living together at the time she was born, but separated when L.J.B. was eleven months old. The Father got married the next year, and filed a complaint with the court seeking increased custody of L.J.B. The relationship between Father and Mother deteriorated once the custody proceedings got started. The Father became threatening and abusive towards the Mother. On approximately eight separate occasions over a three year span, the Father took L.J.B. to the emergency room claiming that she had been sexually abused by the Mother. In each visit to the hospital, the child was subjected to intrusive pelvic exams and pelvic cleaning. None of the exams revealed any evidence of sexual or physical abuse. After a January, 2006 exam, a state caseworker sent a memorandum to the judge overseeing the parentsâ custody case threatening to open an abuse investigation if the Father continued to have L.J.B. âunnecessarilyâ examined or cleaned. Notwithstanding the caseworkerâs concerns over the Fatherâs conduct, the custody court held a hearing concerning the Fatherâs petition for primary physical custody over L.J.B. While psychological evaluations of the parents and child and the custody hearing were still pending, the Mother abruptly dropped off L.J.B. with their Father and moved to Tennessee. She would later explain that she felt she had no choice but to give up on the custody battle to protect L.J.B. from being subjected to additional pelvic exams. Upon the Motherâs relocation, the custody court viewed the litigation over primary physical custody as moot, and granted the Father sole physical custody of L.J.B. The custody judge voiced his disgust over what he viewed as the Motherâs abandonment of L.J.B., and went so far as to suggest that the Father seek to have motherâs parental rights terminated. At the termination hearing, the Mother testified about the pelvic exams and that the custody court refused to put a stop to them. She testified why she left the state as the only way to save L.J.B. from the exams. The Father and his wife denied any wrongdoing. The court terminated the Motherâs parental rights. The Mother appealed to the Superior Court, contending that the termination court erred in finding the Father proved by clear and convincing evidence that her parental rights should have been terminated. The Superior Court affirmed the termination. The Mother petitioned the Supreme Court for an allowance of appeal. The Supreme Court granted the Mother an appeal, finding that the judges in the lower courtsâ âclear antagonism towards Mother [was] evident from the record.â The Court held that the petition to terminate Motherâs parental rights should be dismissed, and that the judges that tried the custody and termination hearings should be recused from further proceedings.

The Court reviewed measures taken in an investigation surrounding the leak of protected information related to a convened grand jury. The grand jury was investigating matters relating to a gambling license application; developments in the investigation appeared in the local newspapers. The Court exercised extraordinary jurisdiction on the allegation that information of the grand juryâs deliberations were leaked to the local press. A Special Prosecutor was appointed, and prepared a report finding that âprocedures adopted by the Office of the District Attorney and left uncorrected by the Supervising Judge were inappropriate and set the stage for improper disclosures.â The Court relinquished jurisdiction, ordered the Special Prosecutorâs report unsealed and sent to the Attorney General for further review.