Justia Pennsylvania Supreme Court Opinion Summaries

This appeal by the Commonwealth, the prevailing party at trial which was aggrieved by the Superior Court's grant of a new trial, centered on principles of self-defense for purposes of assessing whether the trial court abused its discretion in excluding evidence of the murder victim's nine-year-old conviction for robbery. The Commonwealth contended, among other points, that the Superior Court's assessment of the evidentiary ruling misapprehended the law governing self-defense. Upon review of the trial court record and the briefs submitted on appeal, the Supreme Court agreed with the Commonwealth and reversed the Superior Court, reinstating the judgment of sentence for first-degree murder, aggravated assault and related offenses in the underlying case. View "Pennsylvania v. Mouzon" on Justia Law

In this appeal, the Supreme Court was presented with two questions: (1) whether a defendant's convictions for first-degree murder and other crimes which rest solely on subsequently recanted out-of-court statements given to police violates the due process guarantees of either the United States or Pennsylvania Constitutions; and (2) whether the confessions of a former co-defendant should have been admitted as evidence as statements against interest under Pa.R.E. 804(b)(3). After careful consideration, the Court held that the recanting witnesses' out-of-court statements to the police were sufficient to sustain Appellant's convictions against a due process challenge. However, because the Court also found that the trial court erred by not allowing other portions of the co-defendant's confessions to be entered into evidence as statements against interest, the Court was "constrained" to vacate Appellant's convictions and remand the case for a new trial. View "Pennsylvania v. Brown" on Justia Law

This direct appeal concerned the Commonwealth Court's jurisdiction over a suit brought by public school employees for injunctive and declaratory relief against the Office of Open Records, seeking to protect the employees' home addresses from disclosure under the Right to Know Law. Due to concerns surrounding the potential disclosure of school employees' names and home addresses under the recently enacted Right-to-Know Law (RTKL), the Pennsylvania State Education Association (PSEA) sought guidance from the Office of Open Records (OOR) in the form of an advisory opinion. The OOR, however, dismissed the request as moot, as it had already issued final determinations directing the release of public records containing school employees' home addresses. Subsequently, numerous RTKL requests were filed with school districts across Pennsylvania, seeking disclosure of the names and home addresses of school employees. Upon discovering that many school districts had not challenged, or would not challenge, the release of such information, PSEA filed a petition for review against the OOR in the Commonwealth Court, seeking preliminary and permanent injunctions prohibiting the disclosure of school employees' names and home addresses and a declaration that such information is exempt from disclosure under the RTKL. PSEA appealed to the Supreme Court, arguing that the Commonwealth Court erred by refusing to exercise its original jurisdiction over their claims for declaratory and injunctive relief. "Plainly, the RTKL, as presently implemented by the OOR, does not provide public school employees with a reliable administrative or judicial method by which to seek redress for action that they believe violates the statutory scheme and/or their constitutional rights. In these unique circumstances, [the Supreme Court had] no difficulty in concluding that it is just and proper for the OOR to be haled into court to address core and colorable issues connected with such treatment at the behest of affected persons and their associations." The Commonwealth Court's decision was vacated and the case remanded for further proceedings. View "Penna. State Education Assn v. Pennsylvania" on Justia Law

Appellants sought a new trial in this medical battery/lack-of-consent case on the ground that the trial court erroneously instructed the jury on the technical elements of battery, particularly the intent to cause a harmful or offensive contact. They further maintained that the charge was erroneous because it instructed the jury that Appellants-Plaintiffs were required to prove that the surgeon who performed the allegedly unauthorized operation did so with the intent to harm. Viewing the jury charge in its entirety, the Supreme Court concluded that it clearly and accurately set forth the law. Contrary to Appellants' contentions, the jury charge did not require proof that the surgeon performed the operation with the intent to harm. Accordingly, the Court affirmed the order of the Superior Court, which affirmed the trial court's entry of judgment on the verdict in favor of Appellees. View "Cooper v. Lankenau Hospital, et al" on Justia Law

Ronald Bole appealed a superior court's order that affirmed an arbitration award that denied him recovery of underinsured motorist benefits. The Supreme Court allowed the appeal to determine whether the rescue doctrine allowed a volunteer firefighter responding to a crash to recover despite finding his injuries were the result of a superseding cause. Upon review, the Supreme Court concluded that Bole could not, and did not disturb the arbitrator's determination. View "Bole v. Erie Insurance Exchange" on Justia Law

Alleging that Appellant Conestoga Title Insurance Company charged more for title insurance than its filed rates permitted, Appellee Nancy A. White asserted three claims against Conestoga in a class action complaint. The Supreme Court granted review to consider whether White was precluded from pursuing all of her claims because Article VII of the Insurance Department Act of 1921 provided her with an exclusive administrative remedy under Section 1504 of the Statutory Construction Act of 1972. Upon review, the Supreme Court reversed in part and affirm in part. Specifically, the Court reversed the Superior Court's order reversing the trial court's dismissal of White's common law claims for money had and received and for unjust enrichment, and the Court affirmed (albeit on different grounds) the Superior Court's order reversing the trial court's dismissal of White's statutory claim brought under Pennsylvania's Unfair Trade Practices and Consumer Protection Law. View "White v. Conestoga Title Insurance Co." on Justia Law

The issue before the Supreme Court in this case concerned the propriety of resolutions adopted by two school boards that reduce the compensation rates for elected tax collectors in an effort to adopt alternative collection methods. "[The Supreme Court] recognize[d] the difficulties faced by the School Boards in periods of financial uncertainty, but it is beyond the boards' power to transform the local tax collection system by reducing compensation levels to such a degree that the elected Tax Collectors are unable to fulfill their responsibilities; such systematic change must come from the Legislature." The Court reversed the ruling of the Commonwealth Court and remanded the case for further proceedings. View "Telly v. Pennridge School Dist." on Justia Law

Mason-Dixon Resorts, L.P. made a direct appeal to the Supreme Court to challenge a Pennsylvania Gaming Control Board decision that awarded a Category Slot Machine 3 slot machine license to intervenor Woodlands Fayette, L.L.C. Upon review, the Supreme Court affirmed: "[w]e have no doubt that there may have been other applicants for this remaining Category 3 license, including appellant, whose facilities may not have been appropriate for the award of a license. Our task, however, is not to determine for ourselves which of the facilities was the best one, but instead to pass upon the specific claims raised, under the standard review established by the Act. . . . finding no error warranting relief, we affirm the Board's Order." View "Mason-Dixon Resorts v. PA Gaming Control Board" on Justia Law

The Pennsylvania Supreme Court accepted certification from the United States Court of Appeals for the Third Circuit to address the exclusiveness of a statutory appraisal remedy provided to minority shareholders in certain merger scenarios under Pennsylvania corporate law. Where there is a fair value dispute, the BCL provides for post-merger judicial valuation or appraisal of the shares. Mitchell Partners, L.P., was a minority shareholder of Irex Corporation. In 2006, Irex participated in a merger structured so that some minority shareholders would be "cashed out" and would not receive an equity interest in the surviving corporation, a wholly owned subsidiary of North Lime Holdings Corporation. Mitchell objected to the acquisition. The merger proceeded nonetheless, and Irex commenced valuation proceedings in state court to address the dispute with Mitchell. Meanwhile, Mitchell pursued common law remedies in a diversity action in federal court, naming as defendants Irex, its directors, most of its officers, and North Lime. The defendants sought dismissal on the ground that, under Section 1105 of the BCL, judicial valuation was the sole remedy available to dissenting shareholders in the post-merger timeframe. A divided three-judge panel of the Third Circuit reversed the superior court in favor of Mitchell. Defendants sought rehearing, and the Governor of Pennsylvania and several business groups moved for leave to file supportive amicus briefs. The Governor expressed particular concern that the Third Circuit had interpreted the BCL's provisions relating to dissenting shareholders' rights in a manner inconsistent with Commonwealth case law. Accordingly, he urged the Third Circuit to grant rehearing and certify a question of law to the Supreme Court. Upon review, the Supreme Court, in response to the certified question, Section 1105 (of the BCL) "precludes postmerger remedies other than appraisal only in the absence of fraud or fundamental unfairness." View "Mitchell Partners, L.P., Aplt v. IREX Corporation" on Justia Law

Appellant Bortela Philistin appealed an order that denied him relief from his criminal convictions and death sentence pursuant to the Post Conviction Relief Act. A jury convicted Appellant of first degree murder and related offenses. In the penalty phase, the jury found the existence of two aggravating circumstances: the victim was a police officer killed in the performance of his duties, and the Appellant knowingly created a grave risk of death to another. The jury found no mitigating circumstances; thus, it returned a death sentence. Appellant raised thirteen claims on appeal pertaining to errors at trial, the sufficiency of the evidence presented against him, and ineffective assistance of trial counsel. The Supreme Court found no merit to Appellant's claims, and affirmed his conviction and death sentence. View "Pennsylvania v. Philistin" on Justia Law