Justia Pennsylvania Supreme Court Opinion Summaries

The issue before the Supreme Court in this case centered on whether a Workers' Compensation employer's insurance carrier should be reimbursed from the Supersedeas Fund for specific payments made to a claimant prior to the ultimate grant of supersedeas. The question turned on whether the relevant payments constituted payments of "compensation" within the meaning of Section 443 of the Workers' Compensation Act (WCA), 77 P.S. 999(a), or, as argued by Appellant Bureau of Workers' Compensation, whether the payments are not reimbursable because they constitute payment of legal costs associated with obtaining a claimant's third-party tort settlement under Section 319 of the WCA, 77 P.S. 671. After review, the Court found no language in either Section 443 or Section 319 that would transform the relevant payments into something other than compensation merely because the amounts of the payments were calculated to compensate the claimant for the costs of recovering the third-party settlement. Accordingly, the Court affirmed the decision of the Commonwealth Court. View "Bureau of Workers' Comp, Aplt v. WCAB(Excelsior Ins.)" on Justia Law

Appellant Donte Thomas directly appealed his death sentence for first degree murder to the Supreme Court. On appeal, he argued prosecutorial misconduct, errors at trial and ineffective assistance of counsel as grounds for reversal. Following a review of the facts and trial court record, the Supreme Court concluded there was no misconduct, no errors by the trial court, and that Appellant received effective assistance of counsel. Accordingly, the Court affirmed Appellant's sentence. View "Pennsylvania v. Thomas" on Justia Law

Following several evidentiary hearings in this post-conviction capital case, the Court of Common Pleas of Berks County (PCRA court) dismissed the petition filed by Appellant Jose Busanet pursuant to the Post Conviction Relief Act. Appellant filed his PCRA petition on September 24, 2004, and amended it on December 14, 2004. Upon Appellant’s motion, the PCRA court judge, who had presided over Appellant’s trial, recused himself from the PCRA proceeding based on general comments the judge had made in an unrelated case, which referenced his frustration with cases involving drug dealing and gun violence in the City of Reading. A new PCRA court judge was assigned to the case. During the next few years, several different counsel withdrew their appearance due to conflicts of interest. Appellant filed amendments to his PCRA petition on September 14, 2007, and January 7, 2009. On February 7, 2011, the PCRA court entered an Order and Opinion, examining thoroughly each of Appellant’s several claims, and denying PCRA relief. In his direct appeal from the denial of PCRA relief, Appellant raised thirteen issues. Upon careful consideration of each of Appellant's issues raised on appeal, the Supreme Court found no error, and affirmed the PCRA Court's dismissal the PCRA petition. View "Pennsylvania v. Busanet" on Justia Law

Following the death of a college student in Shippensburg, Hearst Television, Inc., d/b/a WGAL-TV and its reporter, Daniel O'Donnell (Requester), filed a Right to Know Law (RTKL) request with Michael Norris, the Coroner of Cumberland County (Coroner), seeking the student's manner of death. The Coroner rejected the request, and the Pennsylvania Office of Open Records (OOR) upheld the Coroner's decision. On appeal, the trial court and the Commonwealth Court affirmed. The Supreme Court reversed, holding that under Section 1236.1(c) of the Coroner's Act and the under the RTKL, the record indicating the manner of death was immediately available to Requester. View "Hearst Television Inc. v. Norris" on Justia Law

The issue on appeal in this case was one of first impression: whether a medical general practitioner who provides incidental mental health treatment to a patient, with whom he then engages in a sexual affair, may be held to a particularized "specialist duty," applicable to mental health professionals, that prohibits consensual sexual contact with patients, such that the defendant general practitioner may be subject to medical malpractice liability in tort. Upon review of the trial court record, the Supreme Court declined to impose such a duty as a matter of Pennsylvania common law. Accordingly, the Court vacated the Superior Court's decision and remanded the case for further proceedings on any preserved issues remain that were not addressed as a result of the Superior Court's disposition. View "Thierfelder v. Wolfert" on Justia Law

This appeal presented a discrete issue of post-trial procedure governed by Rule 227.1 of the Pennsylvania Rules of Civil Procedure, which requires a party to file posttrial motions with the trial judge within ten days of certain enumerated events, with the failure to so file resulting in the significant consequence of a waiver of issues on appeal. The specific question presented was whether a party must file post-trial motions in a remand scenario -- here, a circumstance where, on remand from the Superior Court, the trial court recalculated a damage award without receiving any additional evidence from the parties. The Superior Court quashed appellants' appeal from the trial court's recalculated damages order, holding that appellants had waived all claims by failing to file a second round of post-trial motions. This implicated the question of whether a trial occurred on remand, thereby triggering the post-trial motion procedure contemplated by Rule 227.1. Upon review, the Supreme Court concluded that the panel erred in deeming appellants' claims to be waived for non-compliance with Rule 227.1. Accordingly, the Court vacated the quashal order below and remanded the case for consideration of the merits. View "Newman Development Group of Pottstown v. Genuardi's Family Markets" on Justia Law

The issue before the Supreme Court was whether the Court of Judicial Discipline ("CJD") erred in permanently removing Lehigh County Magisterial District Judge MaryEsther S. Merlo ("Appellant") from judicial office. After careful consideration, the Court found the CJD's sanction was lawful under the circumstances of this case. With regard to Appellant's work habits, the CJD concluded her practice of repeatedly calling off and consistently arriving late constituted a violation of MDJ Rule 4C, and that her conduct was "so extreme as to bring the judicial office into disrepute," constituting a violation of Pa. Const. art. V, sec. 18(d)(1). The CJD further determined Appellant's repeated absences, repeated continuances, and failure to dispose of truancy cases and sign paperwork in a timely manner demonstrated that she did not devote the time necessary for the prompt and proper disposition of the business of her office, in violation of MDJ Rule 3A, and that she neglected and failed to perform the duties of her office, again in violation of Pa. Const. art. V, sec. 18(d)(1). Finally, the CJD concluded Appellant's conduct violated the mandate of MDJ Rule 5A that a magisterial district judge diligently discharge her administrative duties and facilitate the performance of the administrative responsibilities of her staff, noting that Appellant's conduct actually interfered with, rather than facilitated, her staff's performance of their responsibilities: "[i]t is beyond hypocritical for a judge who repeatedly fails to appear, or consistently appears late, for scheduled court proceedings to lecture and impose sanctions upon a juvenile who is appearing before the judge due to truancy issues. Such conduct undermines the very purpose of the proceedings and makes a mockery of the judicial system." The Supreme Court affirmed the decision of the CJD removing Appellant from judicial office and precluding her from holding judicial office in the future. View "In Re: Maryesther S. Merlo, Magisterial District Judge" on Justia Law

Appellant Aaron Jones' third petition for PCRA relief was denied as untimely, and he appealed to the Supreme Court. Appellant was convicted of first degree murder and sentenced to death for ordering the murder of a rival gang member. After multiple unsuccessful attempts to get PCRA relief, Appellant filed an unsuccessful petition for the writ of habeas corpus. When that too was denied, Appellant filed a third PCRA petition, alleging that he received newly-discovered evidence and that his untimely petition should be excepted from the PCRA's timeliness requirement. Upon review, the Supreme Court found no merit to Appellant's arguments, and ruled that his petition was clearly untimely and properly dismissed by the PCRA court. View "Pennsylvania v. Jones" on Justia Law

The Supreme Court granted review of this case to address the applicability of Section 9543(b) of the Post Conviction Relief Act (PCRA) to delays in filing amended post-conviction petitions, and the related issue of what obligation (if any) a petitioner had to move the litigation of his petition forward. In 1988, Petitioner filed a pro se application for post-conviction relief. A public defender was appointed to serve as his counsel upon remand to the PCRA court, but no further docket entries appeared in Petitioner's case until 2003 when Petitioner acting pro se filed a document seeking "extension of post-conviction relief petition." The extension was treated as an untimely and successive PCRA petition. On remand, the case was again assigned counsel, and that counsel filed an amended PCRA petition, raising numerous claims regarding Petitioner's trial counsel's ineffective assistance. The PCRA court issued an opinion dismissing the matter with prejudice. The court cited that too much time as passed to be able to mount a defense as fifteen witnesses were no longer available: "the absence of witnesses as well as the likelihood that memories would be poor twenty-four years after trial… would severely prejudice the Commonwealth's ability to retry" Petitioner. Accordingly, the PCRA court dismissed the matter; the Superior Court affirmed. Upon review the Supreme Court affirmed, concluding that the Legislature balanced policy concerns implicated by protracted litigation of PCRA claims and determined that in certain instances of substantial delay, the prejudice suffered by the Commonwealth as a result of that delay, as demonstrated at an evidentiary hearing, justifies dismissal of an original or amended petition. View "Pennsylvania v. Renchenski" on Justia Law

The Supreme Court granted allowance of appeal in this case to determine whether the immunity provisions of Section 23 of the Workers' Compensation Act (Act 44) applied to "subrogation and/or reimbursement claims sought against an employee who has entered into a third[-]party settlement with a Commonwealth [p]arty such as Southeastern Pennsylvania Transportation Authority ('SEPTA')." Upon review of this matter, the Supreme Court held that the portion of Act 44 at issue in this case barred any claim made by the employer for the recoupment of workers' compensation benefits it paid. View "Fraizer v. W.C.A.B." on Justia Law