Justia Pennsylvania Supreme Court Opinion Summaries

The case involves Lamarcus Eugene Drayton, who was charged with multiple counts of sexual assault against his nephew. The case proceeded to a jury trial, where Drayton was found guilty on all charges and sentenced to an aggregate term of 10 to 20 years' imprisonment, followed by five years' probation. Drayton appealed, asserting that the verdict was against the weight of the evidence, and that the trial court erred when it excluded an alleged prior inconsistent statement by the victim. The Superior Court affirmed the judgment of sentence, and Drayton did not seek further review.Drayton later filed a petition under the Post Conviction Relief Act (PCRA), asserting that his trial counsel was ineffective for failing to object when the court sent written instructions to the jury in violation of Pennsylvania Rule of Criminal Procedure 646, and for failing to call three witnesses whom Drayton claimed would have testified that he had no opportunity to commit the sexual offenses. The PCRA court dismissed Drayton’s petition, and the Superior Court affirmed the dismissal.The Supreme Court of Pennsylvania granted review to consider whether trial counsel’s failure to object, when a trial court provides certain written instructions to the jury during deliberations in contravention of Pennsylvania Rule of Criminal Procedure 646, constitutes ineffective assistance of counsel per se such that a PCRA petitioner need not establish prejudice in order to obtain relief. The court held that counsel’s failure to object to a Rule 646 violation is not one of the limited bases establishing ineffectiveness per se. Accordingly, the court affirmed the decision of the lower courts. View "Commonwealth v. Drayton" on Justia Law

In this case, the plaintiff, Beverly Ferraro, slipped and fell at a Burger King restaurant in Butler County, Pennsylvania, and filed a negligence lawsuit against the restaurant's operators. Ferraro filed her complaint within the two-year statute of limitations for negligence actions. However, she encountered difficulties in serving the complaint to the defendants, Patterson-Erie Corporation D/B/A Burger King and Burger King Corporation, due to issues with the Sheriff's service and the COVID-19 pandemic. Ferraro eventually served the complaint through a private process server and later reinstated the complaint and served it through the Sheriff, but this occurred after the original statute of limitations period had elapsed.The defendants argued that the action was barred by the statute of limitations because Ferraro did not make a good faith effort to serve them in a timely manner. The trial court denied the defendants' motion for judgment on the pleadings, and the Superior Court affirmed this decision. The defendants appealed to the Supreme Court of Pennsylvania, arguing that the lower courts' conclusions conflicted with previous court rulings on the issue of timely service of process.The Supreme Court of Pennsylvania reversed the order of the Superior Court. The court held that Ferraro failed to meet her burden of demonstrating that she made a good faith effort in diligently and timely serving process on the defendants. Therefore, the defendants' informal receipt of actual notice was irrelevant. The court emphasized that plaintiffs cannot opt out of the rules to give notice of the commencement of a lawsuit by informal means. If attempts at service of process are optional for giving such notice, then no plaintiff would be required to rely on the service of process rules to impart notice. View "Ferraro v. Patterson-Erie" on Justia Law

The case involves Earl John and Christine Dwyer, who sued Ameriprise Financial, Inc. for negligent and fraudulent misrepresentation. In 1985, Ameriprise fraudulently and negligently induced the Dwyers to purchase a universal whole life insurance policy by misrepresenting that their quarterly premium payments would remain the same for the life of the policy. The Dwyers surrendered life insurance policies they had purchased from other companies to facilitate this purchase. In reality, if the Dwyers’ premium payment had remained the same, the policy would have lapsed for insufficient funds in 2020.The trial court found Ameriprise guilty of violating Pennsylvania’s Unfair Trade Practices and Consumer Protection Law (CPL) and awarded the Dwyers compensatory damages. However, the court declined to award treble damages under the CPL, reasoning that they would be duplicative of the punitive damages awarded by the jury on the common-law claims. The Superior Court affirmed this decision.The Supreme Court of Pennsylvania disagreed with the lower courts' decisions. The court held that treble damages under the CPL are a separate remedy available to the Dwyers and must be considered by the trial court without regard to a punitive damages award on related common-law claims. The court concluded that nullifying the availability of a statutory award because of a common-law award is not a permissible exercise of discretion. Therefore, the court reversed the order of the Superior Court and remanded the case for reconsideration of damages under the CPL. View "Dwyer v. Ameriprise Financial" on Justia Law

In this appeal, the Pennsylvania State Education Association (PSEA) challenged a resolution issued by the Public School Employees’ Retirement Board (PSERB), which addressed how it intended to apply a statute related to the withdrawal of public school employees from a multi-employer pension system. The Commonwealth Court dismissed PSEA’s action for lack of standing. The court held that PSEA had not shown a substantial, direct, and immediate interest in PSERB’s action or inaction, as PSEA's true dispute was with school district employers over subcontracting, not with PSERB.However, the Supreme Court of Pennsylvania reversed this decision, finding that PSEA did have standing to challenge the resolution. The Supreme Court held that PSEA’s interest in the issue was substantial as it far exceeded the interest of the public at large in the correct application of the statute. The court also found that PSEA’s interest was direct because the resolution was causally connected to the harm PSEA alleged in its ability to effectively negotiate over subcontracting decisions. Additionally, the court found that PSEA’s interest was immediate because the causal connection was real and concrete, not remote or speculative. The court noted that PSEA's averments established a substantial, direct, and immediate interest sufficient to warrant a request for the sort of remedy that a declaratory judgment action seeks—a clarification of the law to resolve a dispute between interested parties over its meaning. Consequently, the Supreme Court of Pennsylvania reversed the Commonwealth Court’s order and remanded the matter to allow PSEA’s action to proceed. View "PSEA v. PSERB" on Justia Law

In this case, the Supreme Court of Pennsylvania was tasked with interpreting the definition of “nudity” as used in 18 Pa.C.S. § 6321. The case involved a minor, T.Q.B., who encouraged another minor, A.D., to lift her shirt during an Instagram live video. A.D., who has an intellectual disability, exposed the bottom portion of her breasts below the nipple area. The rest of A.D.’s breasts, including the nipple, were covered by a bra. T.Q.B. was charged with transmission of sexually explicit images by a minor, a second-degree misdemeanor under 18 Pa.C.S. § 6321(c). T.Q.B. argued that the nudity element of the statute had not been established because the nipple was not exposed.The trial court adjudicated T.Q.B. delinquent, interpreting the statute to cover the exposure of any part of the breast below the nipple. On appeal, the Superior Court affirmed, determining that the term "nudity" in the statute does not require that the nipple must be exposed for the offense to be committed.The Supreme Court of Pennsylvania affirmed the lower courts' decisions. The court found that the language of Section 6321(g) does not require exposure of the nipple to establish the element of nudity. The court held that nudity is sufficiently established where any area below the top of the nipple is visible. The court concluded that the clear language of the statute and the evidence presented at the adjudication hearing established the nudity requirement, and affirmed the Superior Court’s dispositional order finding the evidence sufficient to support T.Q.B.’s adjudication of delinquency. View "In the Int of: T.Q.B., a Minor; Apl of: T.Q.B." on Justia Law

A case in the Supreme Court of Pennsylvania involved a dispute over the termination of a charitable trust. The trust was established by Richard H. Wells in 1965 for the sole benefit of his alma mater, the Virginia Military Institute (VMI), with the Virginia Military Institute Foundation (the “Foundation”) named as the beneficiary. Since its inception, the Trust has been managed by an independent corporate trustee, PNC Bank. The Foundation sought to terminate the Trust and receive the assets outright, arguing that it could manage the Trust with fewer expenses and higher returns.The lower courts denied the termination, concluding that the burdens of the Trust did not meet the statutory criteria for termination under Section 7740.3(e) of the Uniform Trust Act. The Foundation appealed to the Supreme Court of Pennsylvania, arguing that the lower courts erroneously considered Wells’ intent to create a trust, which the Foundation claimed was not relevant under the statute.The Supreme Court of Pennsylvania affirmed the lower courts’ decision. The court held that the Foundation failed to satisfy the statutory standard under Section 7740.3(e) of the Uniform Trust Act, which requires a showing that the administrative expenses or other burdens of the trust are unreasonably out of proportion to the charitable benefits. The court concluded that the expenses and burdens of the trust, including an annual excise tax and mandatory annual distribution under the Private Foundation Rules of the Internal Revenue Code, were not unreasonably out of proportion to the trust's charitable benefits. View "In Re: Trust B of Wells; Apl of: V.M.I. Foundation" on Justia Law

The primary issue in this complex case concerned a man, Ronnie Lehman, who was residing at a residential program called the Renewal Center as a condition of his parole. While there, he was discovered unresponsive due to a drug overdose, and a search revealed possession of illegal drugs. He was charged under Section 5123(a.2) of the Crimes Code, which prohibits a prisoner or inmate from unlawfully possessing a controlled substance. Lehman's legal team argued that he didn't qualify as an "inmate" under this law because he was on parole and voluntarily living at the Renewal Center.The Supreme Court of Pennsylvania disagreed, concluding that Lehman did qualify as an "inmate" under Section 5123(a.2), (e) of the Crimes Code at the time he unlawfully possessed a controlled substance. The court reasoned that the term "committed to" in the statute didn't necessarily imply forceful or involuntary commitment, and could encompass Lehman's situation where he agreed to reside at the Renewal Center as a part of his parole conditions. Therefore, the court held that the evidence was sufficient to sustain Lehman's conviction under Section 5123(a.2), and reversed the judgment of the Superior Court which had granted Lehman post-conviction relief. View "Commonwealth v. Lehman" on Justia Law

The Supreme Court of Pennsylvania held that the Pennsylvania Interscholastic Athletic Association (PIAA) is subject to the Right to Know Law’s record-disclosure mandates. The PIAA is a non-profit corporation and voluntary-member organization which organizes interscholastic athletics and promotes uniform standards in interscholastic sports. In 2020, Simon Campbell, a private citizen, filed a records request under the Right to Know Law seeking eight categories of records from the PIAA. The PIAA objected, asserting it is not a Commonwealth authority or entity subject to the Right to Know Law, and noted its intent to litigate the issue. The court found that the inclusion of PIAA in the definition of a state-affiliated entity, a subset of the definition of a Commonwealth agency, indicates that the General Assembly intended to subject PIAA to the Right to Know Law's record-disclosure scheme. Furthermore, the court found that the General Assembly did not mean the phrase "Commonwealth entity" to be strictly limited to official government agencies. Instead, the Assembly intended the phrase to include organizations that perform some role associated with statewide governance. View "Pennsylvania Interscholastic Athletic Association, Inc. v. Campbell" on Justia Law

In the Commonwealth of Pennsylvania v. Daniel D. Chisebwe, the Supreme Court of Pennsylvania considered whether the evidence was sufficient to support the summary convictions of Daniel Chisebwe for violating two provisions of the Motor Vehicle Code: 75 Pa.C.S. §1511 (Carrying and exhibiting driver’s license on demand) and 75 Pa.C.S. §1311 (Registration card to be signed and exhibited on demand). Chisebwe repeatedly refused to produce his driver’s license and registration card after being stopped for speeding and did so only about twenty-five minutes into the traffic stop, when the police were about to remove him from his car and take him to the police station.The Court held that the evidence was sufficient to support the convictions. The Court found that the phrase "upon demand" in the relevant statutory provisions required Chisebwe to produce his driver’s license and registration card immediately or nearly immediately when requested by a police officer. Chisebwe's delayed production of these documents, about twenty-five minutes into the traffic stop, was far from prompt and therefore did not satisfy the statutes.The Court also held that the safe-harbor provisions of the statutory provisions did not apply to Chisebwe. These provisions permit a driver to produce his license and registration card either at the office of the police officer or the office of the issuing authority, which did not happen in this case. Instead, Chisebwe produced the documents on the side of the road, which did not comport with the specific office-production requirements of the safe-harbor provisions. The Court affirmed the order of the Superior Court upholding Chisebwe’s judgment of sentence. View "Commonwealth v. Chisebwe" on Justia Law

The Supreme Court of Pennsylvania upheld a township ordinance that regulated the discharging of firearms within the township, except at indoor and outdoor shooting ranges. The plaintiff, a resident of the township, challenged the ordinance, claiming it violated his Second Amendment rights by limiting his ability to practice and maintain proficiency in firearm use. The court determined that the ordinance does not violate the Second Amendment. Applying the historical tradition test outlined by the United States Supreme Court in New York State Rifle & Pistol Assoc., Inc. v. Bruen, the court found the ordinance to be consistent with the nation's historical tradition of firearm regulation, which includes restrictions on when and where firearms can be discharged. The court also found that the ordinance does not interfere with the plaintiff's right to bear arms as it does not prevent him from owning or possessing firearms, but simply regulates where they can be discharged. The court also noted that the ordinance allows for shooting ranges in certain areas of the township, providing opportunities for individuals to gain proficiency in firearm use. View "Barris v. Stroud Township" on Justia Law