Justia Pennsylvania Supreme Court Opinion Summaries

Appellant Robert Rega was convicted of first-degree murder and other offenses for the shooting death of Christopher Lauth. Appellant received the death penalty. Appellant filed an application for post-conviction relief which was ultimately denied. On appeal, he raised eleven claims of error. The Supreme Court took each in turn, found no error, and affirmed the denial of post-conviction relief. View "Pennsylvania v. Rega" on Justia Law

Appellee Jack Fortenbaugh was charged with rape and related offenses for the sexual abuse of his stepdaughter. The Supreme Court found that the superior court erred by overturning the jury's verdict in this case and vacating Appellee's sentence based on two references during trial testimony that Appellee take a polygraph test. Because the Supreme Court found those references were not prejudicial, it reversed the superior court's order to reinstate Appellee's original sentence. View "Pennsylvania v. Fortenbaugh, II" on Justia Law

Petitioners Senior Judges John Driscoll and Sandra Moss, and Judges Joseph O'Keefe and Arthur Tilson sought to nullify the mandatory retirement provision applicable to judicial officers as enumerated in the Pennsylvania Constitution. The judges argued that they were elected and then retained to ten-year judicial terms, and that enforcement of the constitutional provision would require them to retire against their will prior to the expiration of those terms. While the Supreme Court recognized "colorable merit" to petitioners' argument that a constitutional amendment may impinge on rights otherwise recognized in the Constitution itself, the Court nevertheless found petitioners did not state a claim upon which relief could be granted, and remanded their case back to the Commonwealth Court to be dismissed. View "Driscoll v. Corbett" on Justia Law

Appellees owned a 166-acre farm in Lower Makefield Township. On December 6, 1996, Lower Maker Township condemned the property in order to build a public golf course. Appellees filed preliminary objections challenging the validity of using eminent domain for such a purpose. That issue was eventually appealed to the Commonwealth Court, which found the taking was for a legitimate public use. As the parties were unable to agree on damages, the matter proceeded to a jury trial for a calculation of the property's value. The trial lasted six days, and a total of 11 witnesses were called, one of whom was appellee Chester Dalgewicz. Mr. Dalgewicz testified regarding the farm's history and the interest shown by several developers in purchasing the property, and described some of the offers received both before and after the property was condemned, including a 1995 agreement of sale with Ryland Homes for $5.1 million, and a 1998 sales agreement with Toll Brothers for $7 million, contingent upon the condemnation being overturned. During Mr. Dalgewicz's testimony, he described a December, 1998 written offer from Pulte Homes, Inc., including a $8 million offer price; the offer letter was also introduced into evidence. The Township objected arguing the offer was inadmissible as it did not result in a sales agreement and any testimony concerning the offer price would be irrelevant and prejudicial. The Township appealed the Commonwealth Court's order affirming the trial court's ruling that testimony regarding a bona fide offer and the underlying offer letter itself could be introduced into evidence in a condemnation valuation trial. Finding no error, the Supreme Court affirmed the lower courts' decisions. View "Lower Maker Township v. Lands of Chester Dalgewicz" on Justia Law

The Supreme Court granted allocatur to determine whether the Superior Court erred by declining to validate a restrictive covenant contained in an employment agreement, solely because the restrictive covenant was not expressly referenced in an initial offer letter which conditioned employment on the execution of the employment agreement. Upon concluding the Superior Court did not properly characterize the offer letter, the Supreme Court vacated and remanded for further proceedings. View "Pulse Technologies v. Notaro" on Justia Law

Appellant Paul Gamboa Taylor appealed the PCRA court's dismissal of his third PCRA petition as untimely and finding trial counsel did not have a conflict of interest during his representation of appellant. Appellant, through PCRA counsel, filed a third PCRA petition alleging, for the first time, at the time he entered his guilty pleas, trial counsel had a conflict of interest which adversely affected his representation of appellant. Appellant contended trial counsel's representation of a a family member of his victim, and that representation was a conflict of interest. Specifically, appellant contended this conflict of interest caused trial counsel to abandon appellant's interests and begin working against him. The Commonwealth filed a motion to dismiss the third PCRA petition as untimely. The PCRA court ultimately determined trial counsel did not have an actual conflict of interest during his representation of appellant. Based on this determination, the PCRA court concluded there was no newly-discovered evidence of a conflict of interest that would bring appellant's petition within one of the PCRA's timeliness exceptions. Accordingly, it found the petition untimely and denied it. Upon review, the Supreme Court agreed, and concluded that the PCRA court properly found appellant failed to satisfy the newly-discovered evidence exception. His third PCRA petition was, therefore, untimely. View "Pennsylvania v. Taylor" on Justia Law

In 2007, police received information from a concerned citizen who witnessed a possible drug transaction at appellee's residence. Police investigation revealed appellee had five prior narcotics arrests, and two prior arrests and one conviction for firearms violations. A confidential informant subsequently told police he knew drugs were being sold from appellee's residence. Based on this information, police applied for and executed a search warrant for appellee's residence. After searching the inside of appellee's home, police recovered three guns, soft body armor, drug paraphernalia, and a small amount of marijuana. Appellee admitted sole possession of the contraband and was charged accordingly. Appellee moved to suppress his post-search inculpatory statements and the evidence seized from his home on the grounds the affidavit for the search warrant failed to establish probable cause. At the suppression hearing, appellee argued the affidavit did not specify where the trash was actually located when police seized it. If the trash was on the curb awaiting collection, it was abandoned, and police could lawfully search it without a warrant; if it was on appellee's porch, appellee retained a privacy interest in it, and the trash pull was unlawful. Accordingly, the trial court held the evidence obtained from the trash pulls was properly included in the affidavit, and it denied appellee's motion to suppress. Regarding appellee's challenge to the trial court's admission of testimony not contained in the affidavit, the Superior Court held the trial court violated Pa.R.Crim.P. 203(D) by considering evidence at the suppression hearing that was outside the four corners of the affidavit of probable cause. The court reasoned: [Appellee] was not challenging the trash pull itself, but rather the existence of probable cause on the face of the affidavit. Thus, the question for the trial court was whether sufficient probable cause existed within the four corners of the affidavit to support the magistrate's decision to issue the search warrant. The court concluded, the trial court was prohibited from hearing supplemental testimony on what it deemed a "second constitutional issue" and then using that evidence to determine whether there was probable cause to issue the warrant. After its review of the matter, the Supreme Court concluded that the Superior Court erred in holding the trial court violated Pa.R.Crim.P. 203(D) in the course of deciding whether a search warrant should have been issued; accordingly, the Court reversed. View "Pennsylvania v. James" on Justia Law

At issue in this case was whether the Commonwealth Court correctly interpreted 24 Pa.C.S. 8507(e) to require that the Public School Employees' Retirement System nomination of benefits form be completed in its entirely in the member/decedent's own hand in order to effectuate a valid change of beneficiary. Upon review, the Supreme Court concluded that the Commonwealth Court erred, and held that the Board correctly determined that under the facts of this case, section 8507(e) allowed for distribution of retirement benefits at issue to the appellant. View "Snizaski v. Public School Employees' Retirement Board" on Justia Law

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