Justia Pennsylvania Supreme Court Opinion Summaries

The case involves Rashaan Londale Greer, who was convicted of first-degree murder and carrying a firearm without a license. After his conviction was affirmed by the Superior Court and his appeal denied by the Supreme Court, Greer filed a Post Conviction Relief Act (PCRA) petition. The PCRA court appointed counsel, who filed several amended petitions before withdrawing her appearance. Greer's second PCRA counsel, Anthony J. Tambourino, filed another amended PCRA petition. After a hearing, the PCRA court denied the amended petition. Tambourino filed a timely notice of appeal and complied with the PCRA court’s order to file a concise statement of errors complained of on appeal.Before the establishment of a briefing schedule, Tambourino filed an application for remand, asserting that Greer had sent him a letter requesting a remand to allow Greer to raise claims of Tambourino’s ineffectiveness. The Superior Court deferred the application for remand to the merits panel and directed Tambourino to file a brief. The Superior Court, in an unpublished memorandum opinion, vacated the PCRA court’s order and remanded the case to the PCRA court. The Superior Court directed the PCRA court to appoint new counsel to develop a record and address any issues Greer had with Tambourino’s stewardship.The Supreme Court of Pennsylvania reversed the Superior Court's order and remanded to that Court for proceedings consistent with its opinion. The Supreme Court held that when a represented petitioner seeks to raise claims against his current counsel while his petition is pending on appeal, an appellate court must remand the case to the PCRA court to have an on-the-record colloquy with the petitioner about his right to counsel, his inability to proceed through hybrid representation, and how he wishes to proceed. The Supreme Court found that the Superior Court erred in ordering a remand without directing the PCRA court to have such an on-the-record discussion. View "Commonwealth v. Greer" on Justia Law

In the case before the Supreme Court of Pennsylvania, the appellant, the Commonwealth of Pennsylvania, challenged the Chester County Court of Common Pleas' ruling that the Sexual Offender Registration and Notification Act (SORNA) was unconstitutional. The appellee, George Torsilieri, had been convicted of sexual offenses and was subject to SORNA's registration and notification requirements. Torsilieri argued that SORNA's presumption that individuals who commit sexual offenses pose a high risk of committing additional sexual offenses was an unconstitutional irrebuttable presumption violating due process. He also contended that SORNA's requirements constituted criminal punishment, which served as the basis for various constitutional challenges.The lower court agreed with Torsilieri, finding that the presumption was not universally true and that the registration and notification requirements were punitive. The court declared Subchapter H of SORNA unconstitutional, and the Commonwealth appealed directly to the Supreme Court of Pennsylvania.The Supreme Court of Pennsylvania reversed the lower court's decision. The court held that Torsilieri failed to establish that SORNA's irrebuttable presumption was constitutionally infirm. The court also concluded that Torsilieri failed to demonstrate that SORNA constituted criminal punishment. Therefore, the court rejected Torsilieri's subsidiary constitutional challenges and reinstated his duty to comply with SORNA. View "Commonwealth v. Torsilieri" on Justia Law

The case involves a dispute over child support between the biological father and the paramour of the child's deceased mother. The biological parents of the child never married, and the mother began a romantic relationship with the paramour while she was pregnant. After the mother's death, the child moved in with the biological father. The paramour, who had been living with the mother and child, filed a complaint for partial physical custody, claiming he stood in loco parentis to the child. The court granted him partial physical custody but no legal custody rights. The biological father then filed a complaint seeking child support payments from the paramour.The trial court dismissed the father's support action, holding that under the precedent set by A.S. v. I.S., the paramour had no obligation to support the child. The Superior Court reversed, holding that the paramour's actions represented a proactive pursuit to assume parental duties of the child that would otherwise belong to the father, and therefore, he had an obligation to support the child.The Supreme Court of Pennsylvania reversed the Superior Court's decision, holding that the paramour is not a "parent" obligated to pay child support. The court held that the paramour does not fit into the class of third-parties obligated to pay support pursuant to the rule announced in A.S. because he does not have legal custody of the child. He has partial physical custody only, which is akin to the visitation rights obtained by the former stepfather in Drawbaugh. The court emphasized that the policy consideration in this case is that expressed in McNutt and Drawbaugh: acts of generosity should not be discouraged by creating a law which would require anyone who begins such a relationship to continue financial support until the child is eighteen years old. View "Caldwell v. Jaurigue" on Justia Law

The case involves Marcus Womack, who was arrested in 2017 following a search warrant executed at a residence in Huntingdon County, Pennsylvania. The search revealed that Womack had been selling drugs from the location, and he was found in possession of a large sum of money, drugs, and a stolen firearm. On the same day, a criminal complaint was filed against Womack, charging him with nine offenses. Unable to post bail, Womack remained in custody. Subsequent investigations revealed that Womack's drug enterprise extended beyond Huntingdon County, leading to the involvement of the Office of the Attorney General (OAG) and a statewide investigating grand jury. In 2018, a second criminal complaint was filed against Womack, charging him with twenty-eight offenses based on evidence gathered during the grand jury investigation.The trial court denied Womack's motion to dismiss the second complaint under Pa.R.Crim.P. 600(D)(1), which requires a trial to commence within 365 days from the date the complaint is filed. Womack's motion to dismiss the first complaint on the same grounds was granted. Womack was found guilty of several offenses in a bench trial on the second complaint and was sentenced to an aggregate term of 39 to 90 years’ imprisonment. He appealed to the Superior Court, arguing that the computation of time for Rule 600 purposes should have been based on the filing date of the first complaint. The Superior Court affirmed the trial court's decision.The Supreme Court of Pennsylvania affirmed the Superior Court’s order denying relief. The court applied the test from Commonwealth v. Meadius, which requires the Commonwealth to demonstrate due diligence between the period in which the complaints were filed, establish that the filing of the second complaint was necessitated by factors beyond its control, and show that its actions were not an attempt to circumvent or manipulate the speedy trial requirements. The court found that the Commonwealth met these requirements, and therefore, the Rule 600 clock began when the second complaint was filed. View "Commonwealth v. Womack" on Justia Law

The case involves a dispute between limited partners and general partners of MBC Properties, LP and MBC Development, LP, two entities engaged in real estate development, investment, acquisition, and management. The general partners appointed a special litigation committee (SLC) to investigate claims made by one of the limited partners, James W. Miller. The SLC recommended that the partnerships should not pursue any action against the general partner or any other third parties. Miller then filed a demand for arbitration, asserting derivative claims and requesting the arbitrator to determine whether the SLC complied with the Pennsylvania Uniform Limited Partnership Act of 2016 (PULPA).The Court of Common Pleas of Schuylkill County granted a petition to permanently stay the arbitration, concluding that Miller's challenge to the SLC report arose statutorily and not under the partnership agreements. The Superior Court vacated the trial court's order, finding that the underlying derivative claims were within the scope of the arbitration agreements and that the determination required by PULPA is a prerequisite and defense to those claims, rather than a cause of action.The Supreme Court of Pennsylvania reversed the Superior Court's decision, holding that the parties' agreements incorporated the plain language of Section 8694 of PULPA, which mandates court review of a special litigation committee's determination. The court concluded that the dispute over an SLC's determination pursuant to the PULPA is not within the scope of the parties' arbitration agreement. The court remanded the case for proceedings consistent with its opinion. View "MBC Development, LP v. Miller" on Justia Law

The Supreme Court of Pennsylvania reviewed a case involving Kevin Dowling, who was convicted of first-degree murder and sentenced to death. Dowling was initially charged with robbery, indecent assault, and attempted rape of Jennifer Myers, who identified him as her assailant. Two days before his trial, Myers was found dead in her art gallery. Dowling was subsequently charged with her murder. At trial, the prosecution argued that Dowling killed Myers to prevent her from testifying against him. The prosecution presented evidence including a video of Dowling’s fabricated alibi, a letter in which he confessed to attacking Myers, and testimony from several witnesses. Dowling was convicted and sentenced to death.Dowling later filed a petition under the Post Conviction Relief Act, alleging that his trial counsel was ineffective for failing to investigate the accuracy of a receipt from a store where a witness claimed to have seen him on the day of the murder. He also claimed that the prosecution violated his due process rights by not disclosing cash register journals from the store, which would have shown that the time on the receipt was correct. The PCRA court granted Dowling a new trial, but the Commonwealth appealed.The Supreme Court of Pennsylvania reversed the PCRA court's decision, concluding that Dowling failed to demonstrate a reasonable probability that the outcome of his trial would have been different had his counsel conducted further investigation or had the prosecution disclosed the register journals. The court also found that the false testimony of a police officer about the time on the receipt could not have affected the judgment of the jury, given the substantial independent evidence incriminating Dowling in Myers’ murder. View "Commonwealth v. Dowling" on Justia Law

The case involves a legal malpractice claim filed by minors N.W.M. and E.M., through their parents, against their former guardian ad litem (GAL), Patrice Langenbach, and her employer, the Defender Association of Philadelphia. The minors alleged that Langenbach acted negligently throughout her representation of them in a dependency matter and a corresponding termination of parental rights matter. The trial court dismissed all claims on grounds of immunity, asserting that Langenbach and the Defender Association were immune from suit under the doctrine of quasi-judicial immunity.On appeal, the Superior Court reversed the trial court's decision, holding that it was not within its authority to extend such immunity to GALs. The Superior Court maintained that it was not its role to make policy decisions or to expand existing legal doctrines, which it considered to be the prerogative of the Supreme Court or the General Assembly.The Supreme Court of Pennsylvania affirmed the Superior Court's decision, concluding that GALs in juvenile dependency cases do not operate as an arm of the court and, therefore, are not entitled to quasi-judicial immunity. The court also clarified that the Superior Court is authorized to address novel legal issues, including those involving policy considerations. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "N.W.M. v. Langenbach" on Justia Law

The Supreme Court of Pennsylvania was asked to clarify the use of hearsay evidence in establishing a prima facie case at a preliminary hearing. The case involved Ronald Harris, who was charged with multiple crimes, including attempted murder. The victim did not appear at the preliminary hearings, and the Commonwealth proceeded with the testimony of two police officers who relayed the victim's out-of-court statements. Harris's counsel objected to the use of hearsay evidence, but the trial court overruled the objections and bound all charges over for trial.Harris filed a motion to quash the charges, arguing that the Commonwealth's case was established solely through hearsay, which he claimed was not legally competent evidence. The trial court granted the motion, and the Commonwealth appealed to the Superior Court, which affirmed the decision. The Superior Court held that all material elements of a criminal offense need to be proved at a preliminary hearing by non-hearsay evidence to avoid violating a defendant's constitutional rights to due process.The Commonwealth appealed to the Supreme Court of Pennsylvania, arguing that the Superior Court's ruling was too broad and that hearsay evidence could be used to establish some elements of the crimes charged. The Supreme Court affirmed the Superior Court's decision but disapproved of its rationale. The Supreme Court held that while hearsay evidence could be used to establish a prima facie case that an offense has been committed, it could not be used alone to prove a prima facie case as to the defendant's identity. The court clarified that the Commonwealth must produce some non-hearsay or admissible hearsay evidence to sustain its prima facie burden as to the defendant's identity. View "Commonwealth v. Harris" on Justia Law

The case involves a dispute between Stewart Kramer and Valerie Concinello (Parents) and Nationwide Property and Casualty Insurance Company (Nationwide) over the interpretation of their homeowners insurance policy. The dispute arose after the fatal drug overdose of Michael T. Murray, Jr. (Decedent) at Parents' home. The administrator of Decedent's estate sued Parents and their son, Adam Kramer, for wrongful death and survival actions. Parents sought coverage under their insurance policy with Nationwide, but Nationwide denied coverage based on a controlled substance exclusion in the policy. Parents then filed a declaratory judgment action, and the trial court ordered Nationwide to defend Parents.The Superior Court affirmed the trial court's decision but based its ruling on a different interpretation of the policy. The Superior Court concluded that the policy's controlled substance exclusion applied to the bodily injury claims in the underlying lawsuit but did not apply to emotional distress damages claimed in the wrongful death action.The Supreme Court of Pennsylvania reversed the Superior Court's decision. The Supreme Court held that the Superior Court's interpretation that Nationwide was potentially required to pay out for emotional and mental distress damages was contrary to the unambiguous provisions of the policy and erroneous as a matter of law. The Supreme Court concluded that Nationwide had no duty to defend the underlying lawsuit because emotional and mental distress damages in the wrongful death claims were not bodily injuries under the policy. View "Kramer v. Nationwide Insurance" on Justia Law

The case involves the Pennsylvania Public Utility Commission (PUC) and the City of Lancaster, Borough of Carlisle, and Borough of Columbia (collectively referred to as the Municipalities). The dispute centers around Section 59.18 of the PUC’s regulations, which gives natural gas distribution companies (NGDCs) the authority to determine the location of gas meters in historic districts. The Municipalities argued that this regulation violates Article II, Section 1 of the Pennsylvania Constitution, which vests legislative power in the General Assembly, not in private entities like NGDCs.The Commonwealth Court agreed with the Municipalities, concluding that Section 59.18 unlawfully delegates legislative authority to NGDCs without providing adequate standards to guide their decisions. The court therefore declared Section 59.18 unenforceable.The PUC appealed this decision to the Supreme Court of Pennsylvania. The PUC argued that Section 59.18 does not delegate legislative power to NGDCs, but rather is a regulatory act under the PUC’s administrative authority. The PUC also contended that the Commonwealth Court failed to consider the safety issues related to meter placement, which is the primary concern of the regulation.The Supreme Court of Pennsylvania reversed the decision of the Commonwealth Court. The court found that the General Assembly never enacted a statute giving the PUC legislative authority to determine the location of gas meters in historic districts. Therefore, the PUC could not have unlawfully delegated this authority to NGDCs. The court concluded that the Municipalities' disagreement with the PUC's regulation does not amount to a constitutional violation. The case was remanded to the Commonwealth Court for further proceedings. View "City of Lancaster v. PUC" on Justia Law