Justia Pennsylvania Supreme Court Opinion Summaries

The issue before the Supreme Court was the proper method of calculating an hourly-wage claimant's average weekly wage under Section 309 of the Workers’ Compensation Act where the specific loss claimant suffered an initial incident, changed employers, and later suffered a work-related injury caused by the initial incident. Claimant Janice Weber-Brown worked for Appellant Lancaster General Hospital as a licensed practical nurse. In 1980, while cleaning the tracheotomy of a patient who was infected with the herpes simplex virus (HSV), the patient coughed, causing sputum to spray in Claimant’s left eye. Approximately two weeks after the incident, Claimant’s eye became swollen and infected, and Claimant believed she contracted HSV. Claimant left the employ of Lancaster General in 1985 for reasons unrelated to the eye incident. At that time, she earned $8 per hour and worked full-time. In the years following her departure from the hospital, Claimant’s eye became infected several more times. Each time, her symptoms subsided with treatment, and Claimant did not miss any work with her other employers due to her eye infections. In October 2006, however, Claimant’s eye again became infected and, this time, her infection did not respond to treatment. By February 2007, Claimant lost the vision in her left eye, and, in May 2007, she underwent a cornea transplant. The transplant did not improve her vision, and, as a result of her blindness, she was not able to return to work. At that time, Claimant earned $21 per hour. Lancaster General denied Claimant's allegations that she contracted HSV while working for the hospital, and challenged her claim that she be paid based on her then-current wage with her new employer. The WCJ determined Claimant suffered a work-related injury and held that the hospital pay Claimant's wage set at $21 per hour. Lancaster General appealed. Upon review, the Supreme Court concluded that the WCJ correctly held that the Claimant's weekly wage should have been based on her 2007 wages with her new employer, as those wages were earned with that employer at the time Claimant suffered her work-related injury. View "Lancaster Gen. Hospital v. WCAB" on Justia Law

The Commonwealth asks the Supreme Court to consider whether the materiality requirement of "Brady v. Maryland" (373 U.S. 83 (1963)), is satisfied where the evidence not disclosed by the Commonwealth and would itself not have been admissible at trial. The Commonwealth further requested the Court reconsider, based on more recent decisions by the Pennsylvania Court and the United States Supreme Court, the Court's holding in "Commonwealth v. Green," (640 A.2d 1242 (1994)). After careful consideration, the Pennsylvania Supreme Court held that nondisclosed favorable evidence which is inadmissible at trial may be considered material for purposes of "Brady," as long as there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different. "Mere speculation by a defendant . . . will not be sufficient to meet this standard; rather, he must identify specific evidence or information that would have been uncovered, and explain how that evidence or information would have changed the result of the proceeding." Notwithstanding its holding, because the Court found in this case that Appellee did not establish there was a reasonable probability that, had the evidence withheld by the Commonwealth been disclosed, there would have been a different outcome at trial, the Court reversed the order of the Superior Court remanding for a new trial, and reinstated Appellee's judgment of sentence. View "Pennsylvania v. Willis" on Justia Law

The Supreme Court granted review in this case to determine whether the courts below erred in dismissing criminal charges against Defendant-Appellee David Bradford. The trial court discontinued the case because the Commonwealth failed to bring Defendant to trial within the time required by Pennsylvania's speedy trial rule (Pa.R.Crim.P. 600) when the Magisterial District Judge failed to forward timely the relevant file as required by Pa.R.Crim.P. 547(B). Upon review, the Court determined that dismissal was not appropriate under Rule 600 when the Commonwealth acted with due diligence in relying upon the judicial system to transfer documents in accordance with the Rules of Criminal Procedure. Accordingly, the Court reversed the dismissal of charges and remanded the case to the trial court. View "Pennsylvania v. Bradford" on Justia Law

Appellant Alexander Keaton appealed the denial of his application for post-conviction relief; the Commonwealth cross-appealed the grant of a new penalty phase based on trial counsel's ineffectiveness for failing to present mitigating mental health evidence. In 1992, Appellant was charged with rape and related offenses stemming from the sexual assault of Nadine S. One month later, the body of Appellant's ex-girlfriend was found. After waiving his rights, Appellant gave a written statement incriminating himself in the killing, and he was charged with murder. Appellant sexually assaulted two other women, making self-incriminating statements. The Commonwealth moved to consolidate the charges for all victims. Over defense objection, the trial court granted the motion. Prior to trial, Appellant moved to suppress his statements; the motion was denied, and Appellant was tried before a jury and found guilty of first degree murder, rape, and related offenses. At the penalty phase, the Commonwealth sought to prove several aggravating circumstances. The jury found no mitigating circumstances and one aggravating circumstance. Accordingly, Appellant was sentenced to death. Appellant timely filed a pro se PCRA petition and received appointed counsel, who filed an amended petition alleging all prior counsel's ineffectiveness for not raising numerous guilt and penalty phase issues. The PCRA court held a hearing on the sole issue of trial counsel's ineffectiveness for failing to investigate and present mitigating evidence at the penalty phase. The PCRA court rejected Appellant's guilt phase claims, and denied him a new trial. However, the court concluded trial counsel was ineffective for failing to develop and present mitigating evidence, and granted a new penalty hearing. The PCRA court's opinion did not address several of the issues in detail, it merely stated it found Appellant's claims of guilt phase error meritless and would not further discuss them; the only penalty phase issue the court addressed was trial counsel's ineffectiveness. Without conclusive findings regarding whether Appellant was mentally retarded, the Supreme Court could not address his "Atkins" claim; accordingly, the Court remanded for the PCRA court to consider that claim's merits. The PCRA court complied, and rejected Appellant's claim of mental retardation. On appeal of that decision, the Supreme Court determined that there was a factual question regarding whether Appellant invoked his Fifth Amendment right to counsel in 1992 when he made his self-incriminating statements. The Court remanded this issue to the PCRA court for determination of this issue and for the parties to address the applicability of the applicable case law if the court determined Appellant did invoke his right. As to Appellant's remaining guilt phase claims, the Supreme Court affirmed the PCRA court's denial of relief. View "Pennsylvania v. Keaton" on Justia Law

The civil action underlying this appeal was selected as a test case for the admissibility of expert opinion evidence to the effect that each and every fiber of inhaled asbestos is a substantial contributing factor to any asbestos-related disease. The inquiry has proceeded under principles derived from 'Frye v. United States' (293 F. 1013 (D.C. Cir. 1923)). Upon its consideration of the evidence presented by both sides, the trial court sustained the Frye challenge and precluded the plaintiffs from adducing the 'any exposure' opinion. Focusing upon methodology, the judge found no support for the any exposure theory of specific causation in any of the sources upon which the expert relied. The Superior Court majority was very critical of the trial court's treatment of the Frye challenge on several fronts. While finding error in the threshold determination, the Superior Court nevertheless proceeded to review the trial court's finding as to general acceptance, concluding that the judge had abused his discretion. At the outset, the Supreme Court concluded the trial court's decision to conduct a Frye hearing concerning the any-exposure opinion to be appropriate. While the Superior Court was correct that the trial court judge did not embellish his opinion with specific citations to the record, his findings and conclusions were 'amply supported throughout that record nonetheless.' The Court concluded that the trial court did not abuse his discretion in its Frye assessment. The order of the Superior Court was reversed, and the case was remanded for consideration of whether there were remaining, preserved issues on appeal which were obviated by the intermediate court's approach to the common pleas court's ruling. View "Betz v. Pneumo Abex LLC" on Justia Law

The Supreme Court granted allocatur in this case to consider the Superior Court's application of the standard of review and to evaluate the relevance of a parent's incarceration to a trial court's decision to terminate a father's parental rights. G.P. (Father), then nineteen, and B.D. (Mother), then approximately seventeen, were involved in an intimate relationship prior to Father's incarceration in December 2004 for the shooting death of his stepfather. While Father was incarcerated, S.P. (Child) was born in May 2005. After Child’s birth, Mother took her to visit Father several times while he was incarcerated at the county prison awaiting trial. In December 2005, Child was declared dependent, when Mother tested positive for THC, a chemical found in marijuana, and was involved in a domestic assault in the presence of Child. Following the declaration of Child’s dependency, Mother and Child apparently moved between several foster homes and Child’s grandmother’s home. In 2007, Child and Youth Services (CYS) filed an emergency shelter petition on behalf of Child when it could not ensure Child's safety. In 2008, Mother voluntarily relinquished her parental rights to Child. At a hearing, testimony was presented that revealed Child suffered from developmental delays and was possibly autistic. A year later at another hearing, CYS moved to terminate Father's parental rights. As applied to this case, the Supreme Court concluded the Superior Court erred in reversing the trial court’s decision to terminate Father’s parental rights: "the trial court did not abuse its discretion when it concluded that “the conditions and causes of the incapacity . . . [could not] or [would] not be remedied” by Father." View "In Re: Adoption of S.P." on Justia Law

Appellant Leroy Thomas (a/k/a John Wayne) appealed an order that denied him post-conviction relief (PCRA). Appellant was convicted by jury of the first degree murder of Kenneth Rankine. At the penalty phase, the jury found one aggravating circumstance: Appellant had been previously convicted of murder. The jury found no mitigating circumstances and sentenced Appellant to death. Appellant filed a direct appeal to the Supreme Court, claiming ineffective assistance of trial counsel and insufficient evidence to support his conviction. The Supreme Court affirmed, finding Appellant failed to establish he received ineffective assistance of counsel, and that the Commonwealth presented sufficient evidence to establish beyond a reasonable doubt he conspired with two others to kill the victim. Appellant then filed a timely pro se PCRA petition, was appointed new counsel, and filed an amended petition. Appellant appealed the denial of his PCRA petition ,raising eight issues. The Supreme Court took each of these issues in turn, and found that Appellant failed to establish the PCRA court abused its discretion in denying Appellant relief. View "Pennsylvania v. Thomas" on Justia Law

Appellant Harve Johnson made a direct appeal to the Supreme Court nunc pro tunc following a jury's imposition of the death sentence for his conviction on first degree murder charges. At the penalty phase, the jury found two aggravating circumstances and one mitigating circumstance. The jury further found the aggravating circumstances outweighted the mitigating circumstance, and sentenced Appellant to death. Appellant raised fourteen issues on appeal, all implicating the admission of certain evidence and sufficiency of the admitted evidence presented at trial. Upon review, the Supreme Court determined the Commonwealth provided sufficient evidence to prove each element of first degree murder. Furthermore, the Court found no abuse of discretion by the trial court in admitting the evidence Appellant complained of at trial. Accordingly, the Court affirmed Appellant's conviction and sentence. View "Pennsylvania v. Johnson" on Justia Law

The Supreme Court allowed this appeal to review a superior court conclusion that a police-citizen encounter ripened into an investigative detention when an officer requested identification from several occupants in a vehicle. In 2007, Appellee John Au was arrested by a Ferguson Township officer and charged with possession of marijuana. Appellee sought the suppression of that evidence. According to the officer’s testimony, it was unusual to see a car in the location at such time, and he decided to make further inquiry. The officer did not activate the emergency lights of his police cruiser, but he positioned his vehicle at an angle relative to the parked automobile so as to illuminate the passenger side. The officer said that he did so without blocking the egress of the vehicle, which he then approached, "probably with a flashlight." The common pleas court awarded suppression of the drug evidence. The court framed the issue as whether the arresting officer had the legal authority to approach the parked vehicle and ask for identification from the occupants when there was no evidence of any criminal activity or a violation of the Motor Vehicle Code. The superior court affirmed. Upon review of the matter, the Supreme Court concluded that the arresting officer’s request for identification did not transform his encounter with Appellee into an unconstitutional investigatory detention. Accordingly, the Court reversed the superior court's order and remanded the case for further proceedings. View "Pennsylvania v. Au" on Justia Law

In this case, the Supreme Court addressed whether there was sufficient probable cause for the issuance of an anticipatory search warrant for Appellant Gregory Wallace's home. After review, the Court concluded conclude there was not and, thus, found the warrant, which authorized a search of Appellant's home after the completion of a controlled purchase by a confidential informant, violated the Fourth Amendment to the United States Constitution, as well as Article I, Section 8 of the Pennsylvania Constitution. The Court therefore reversed the order of the Superior Court and reinstated the order of the trial court which suppressed evidence seized from Appellant's home. View "Pennsylvania v. Wallace" on Justia Law