Justia Pennsylvania Supreme Court Opinion Summaries

Appellant, in his capacity as vice-president of Izett Manufacturing, Inc., executed a guaranty in connection with a loan agreement entered into by the company. The loan agreement entitled Izett Manufacturing to borrow up to $50,000 and was secured by a promissory note. The note and the guaranty both were dated 1999, and Appellant personally guarantied the payment of all liabilities under the note. The guaranty included a confession of judgment clause and stated that it was "executed under seal," with the designation "(SEAL)" as part of the signature line. By 2001, the company had borrowed $50,000 under the agreement. At that time, Appellee Osprey Portfolio, LLC purchased the loan and was assigned the note and guaranty. In late 2005, Osprey sent a letter to Izett Manufacturing, declaring the loan to be in default and demanding payment in full. Izett failed to remit payment. More than four years later, Osprey filed a Complaint in Confession of Judgment against Appellant as the guarantor of the loan. The court entered judgment the same day. Thereafter, Appellant filed a Petition to Strike and/or Open Judgment, claiming, in relevant part, that Osprey's action was precluded by Section 5525(a)(8) of the Judicial Code, which establishes a four-year limitation period for "[a]n action upon a contract, obligation or liability founded upon a writing . . .under seal . . ." The Supreme Court allowed this appeal to determine the limitation period that applies to an action on a guaranty executed under seal. Upon review, the Court held that the loan guaranty executed under seal by Appellant was an "instrument in writing under seal" subject to a 20-year limitation period set forth in Section 5529(b)(1) of the Judicial Code. Therefore, the Superior Court was affirmed. View "Osprey Portfolio, LLC v. Izett" on Justia Law

The Supreme Court granted allocatur to consider whether a probation condition authorizing warrantless, suspicionless searches of a probationer's home violated statutory and constitutional precepts. In 2007, a Philadelphia police officer observed appellant standing next to a parked automobile. Appellant was pointing a handgun through the passenger window at the driver. The police officer ordered appellant to drop his weapon. Appellant did not comply, but instead, gun in hand, retreated to a nearby residence. The police officer repeated his demand that appellant drop his weapon. Appellant finally complied, and placed himself on the ground in compliance with the officer's direction. The police officer, and a second officer who arrived on the scene in response to a call for back up, retrieved a loaded .38 caliber revolver. Police also recovered seven packets of marijuana and five packets of cocaine from appellant. The trial court instead sentenced appellant to a mitigated-range sentence of 2.5 to 5 years' incarceration, to be followed by three years' probation. The trial court emphasized that there was no stricter probation than Gun Court probation. As a condition of probation and of parole, the trial court authorized warrantless, suspicionless searches of appellant's residence for weapons, and prohibited him from residing in a household where anyone had a firearm. In matters that raise both constitutional and non-constitutional bases for relief, the Supreme Court attempts to resolve matters on non-constitutional grounds as practicable. In this case, the Court found under the applicable statutory construct of this case, sentencing courts were not empowered to direct that a probation officer may conduct warrantless, suspicionless searches of a probationer as a condition of probation. As such, the probation condition ordered in this case was vacated to the extent that the sentencing court found it permissible, and the case was remanded for resentencing. View "Pennsylvania v. Wilson" on Justia Law

Appellant Laquaille Bryant directly appealed his death sentence to the Supreme Court, seeking a new penalty-phased hearing on three grounds: (1) the Suppression Court erred in denying a motion to suppress; (2) the court erred in permitting "extremely inflammatory and prejudicial" photographs of the victim, introduced at the penalty phase hearing; and (3) due to prosecutorial misconduct. Finding no error, the Supreme Court affirmed Appellant's verdict and death sentence. View "Pennsylvania v. Bryant" on Justia Law

This case stemmed from the underground leaking of gasoline from a gasoline station in Blue Bell, Pennsylvania, which caused an explosion in the springhouse of a realty office situated across the street. Many thousands of gallons moved underground throughout the surrounding neighborhoods. Pursuant to Pennsylvania Rule of Civil Procedure 2229(a), 45 affected individuals filed a single complaint against six defendants, alleging that gasoline and vapor from the leak had traveled underground, through soil and groundwater, and had reached and entered their homes, causing property damage to their homes and illness to those living there. At issue before the Supreme Court was whether the Superior Court erred in holding that the trial court abused its discretion in ordering a separate trial of the claims of four test-case, or “bellwether” plaintiffs, from among the 45 plaintiffs. The Court concluded that the Superior Court erred. Furthermore, the Supreme Court held that the Superior Court erred in determining that the trial court abused its discretion in severing the claims in the interest of convenience and judicial economy. The order of the Superior Court was reversed and the jury verdict was reinstated. View "Ball, et al v. Bayard Pump Co." on Justia Law

Appellant Sabrina Bowman appealed a Superior Court’s order affirming the Court of Common Pleas of Philadelphia County, which granted Sunoco, Inc.'s motion for judgment on the pleadings and dismissed appellant's negligence claim. Appellant was employed as a private security guard with Allied Barton Security Services. In exchange for employment, she signed a Workers' Compensation Disclaimer whereby she waived her right to sue Allied's clients for damages related to injuries covered under the Workers' Compensation Act. Appellant was later injured when she fell on ice and snow while working at one of Sunoco's refineries. She filed a workers' compensation claim and received benefits. Thereafter, appellant filed a negligence claim against Sunoco, alleging failure to maintain safe conditions caused her injury. After discovery revealed the disclaimer and appellant's receipt of benefits, appellee filed a motion for judgment on the pleadings, stating appellant's claim was barred by the disclaimer. Finding no error in the Superior Court's decision, the Supreme Court affirmed. View "Bowman v. Sunoco, Inc." on Justia Law

Appellant Stephen Edmiston appealed the denial of relief on two separate Post-Conviction Relief Act (PCRA) petitions: (1) the denial of relief raised in his second PCRA petition; and (2) the denial of his request for post-conviction DNA testing in support of his motion for petition. Upon review, the Supreme Court found that the claims Appellant raised regarding the second petition were untimely. Further more, the Supreme Court affirmed denial of post-conviction DNA testing because Appellant failed to demonstrate that his DNA petition was made "in a timely manner and for the purpose of demonstrating [his] actual innocence and not to delay the execution of sentence or administration of justice." View "Pennsylvania v. Edmiston" on Justia Law

Appellees filed an original-jurisdiction petition for review challenging recent changes to the Department of Public Welfare's practices and policies in determining appropriate reimbursement of county expenditures for out-of-home, child-welfare placement services. According to the petition, the reimbursement scheme as published in the Code, Department regulations, and in previous administrative practices, embodied a needs-based budgeting process supplemented by compliance review via intermittent auditing of county and service provider records by the state agency. Appellees contended however, that DPW through a series of recent administrative bulletins, had unilaterally and inappropriately substituted a restrictive, statewide rate-setting process in place of the prior regime. Appellees lodged substantive and procedural challenges, claiming that the changes effected by the bulletins were ultra vires and unconstitutional, or, alternatively, that DPW had failed to comply with mandatory regulatory-review procedures designed to ensure a meaningful opportunity for public participation and independent regulatory oversight. Upon review, the Supreme Court concluded that the Commonwealth Court did not err in concluding that the bulletins contained procedurally invalid legislative regulations. View "NW Youth Svcs. v. Dept. Pub. Welfare " on Justia Law

Appellant Lewis Jordan, a/k/a John Lewis, pled pled guilty to murder generally in the shooting death of Philadelphia Police Officer Charles Cassidy. Following a trial by jury to determine degree of guilt, Appellant was convicted of first-degree murder and sentenced to death. In a direct appeal, Appellant raised four issues. Concluding that Appellant was not entitled to relief on any of these issues and that the evidence was sufficient to sustain Appellant's conviction, the Supreme Court affirmed the judgment of sentence. View "Pennsylvania v. Jordan" on Justia Law

The issue before the Supreme Court in this case centered on whether a deed executed in 1881 reserving the subsurface and removal rights of "one half of the minerals and petroleum oils" in the grantor included any natural gas contained within the shale formation beneath the subject land. The trial court, relying on the 1882 Supreme Court decision "Dunham & Shortt v. Kirkpatrick," (101 Pa. 36 (Pa. 1882)) and its progeny, held that because the deed reservation did not specifically reference natural gas, any natural gas found within the Marcellus Shale beneath the subject land was not intended by the executing parties to the deed to be encompassed within the reservation. The Superior Court reversed that decision and remanded the case with instructions to hold an evidentiary hearing complete with expert, scientific testimony to examine whether: (1) the gas contained within the Marcellus Shale was "conventional natural gas"; (2) Marcellus shale was a "mineral"; and (3) the entity that owns the rights to the shale found beneath the property also owns the rights to the gas contained within that shale. Upon review, the Supreme Court reversed, finding that the Superior Court erred in ordering the remand for an evidentiary hearing and reinstated the order of the trial court. View "Butler v. Charles Powers Estate" on Justia Law

In 2005, Appellees Monroe County Detective Eric Kerchner and First Assistant District Attorney Michael Mancuso were investigating and prosecuting Dennis Slayton for theft and drug-related offenses, as well as Jill Goldstein in connection with the drug offenses. Appellant John P. Karoly, Jr., Esq., was acting as Slayton's attorney. Goldstein appeared at a bail revocation hearing represented by Eric Dowdle, Esq. At the conclusion, bail was revoked and Goldstein was placed in custody at the Monroe County Correctional Facility (MCCF). The next day, Goldstein called Slayton from the jail. During the conversation, Appellant, who was with Slayton, began speaking with Goldstein. The MCCF recorded the conversation. In a direct appeal involving alleged intentional violations of the Wiretap Act, the issue before the Supreme Court was whether the Commonwealth Court erred in granting a defense motion for summary judgment. In the amended complaint, Appellant alleged that Appellees committed multiple violations of the Wiretap Act, most notably that: ADA Mancuso violated Section 5703(2) of the Act by disclosing the conversation between Appellant and Goldstein when he included it in legal filings that were not placed under seal; and ADA Mancuso and Detective Kerchner conspired to transmit such filings to the press. On the basis of this conduct, Appellant asserted that Appellees intentionally violated the statute and, as such, should be removed from their employment pursuant to Section 5726. "In [this] context, the most obvious manner of accomplishing the appropriate investigative and law-enforcement use of the intercepted conversation . . . would have been to file the motion and brief under seal. The failure to do so, as all parties acknowledge, caused the intercepted conversation to become a matter of public record." The Supreme Court found that the Commonwealth Court did not evaluate whether the unsealed filing of the motion and brief was permissible under Section 5717. Because this issue, as well as an appropriate treatment of the alleged disclosure to the press, were material to the outcome, the Court found that the Commonwealth Court improperly granted Appellees' motion for summary judgment. Thus, the case was remanded for hearings on these questions, the question of intent, and/or on whether Appellees acted in good-faith reliance on the Act. View "Karoly v. Mancuso" on Justia Law