Justia Pennsylvania Supreme Court Opinion Summaries

Appellant Ernest Porter appealed a common pleas court order that denied his serial petition under the Post Conviction Relief Act (PCRA). Appellant was sentenced to death for the murder of Raymond Fiss in 1985. After his appeal was was briefed on the timeliness merits and submitted, the parties, upon direction of the Supreme Court, filed supplemental briefs addressing the jurisdictional issue of whether the PCRA court's order was final and appealable. Upon review, the Supreme Court determined that the common pleas court's order was appealable and that the court's time-bar determination was correct. With this case, the Supreme Court took the opportunity to address: (1) the circumstances creating uncertainty respecting appealability, in an effort to ensure that those circumstances do not arise again; and (2) the circumstances creating the unacceptable delay in this case, so that PCRA courts throughout Pennsylvania will take measures to avoid such delays. Though the Court affirmed the PCRA court's decision with regard to the time-bar determination, the case was remanded to direct the PCRA court to promptly dispose of Appellant's long-pending prior PCRA petition which raised an issue under "Atkins v. Virginia," 536 U.S. 304 (2002). View "Pennsylvania v. Porter" on Justia Law

The trial court in this case denied Jane Doe's (a minor) application for judicial authorization for an abortion, reasoning, in significant part, that because the minor did not seek parental consent she was not "mature and capable" of giving informed consent independently. The Superior Court affirmed the trial court’s denial of judicial authorization, finding no abuse of discretion. In this appeal, the Supreme Court examined the standard of review applicable to the trial court's denial, and had to determine whether the trial court may, under Pennsylvania law, deny judicial authorization based upon the minor’s failure to obtain parental consent. Upon review of the particular facts of this case, the Supreme Court held that the appeal would be reviewed under the "abuse of discretion" standard. Additionally, the Court held that a trial court lacks statutory authority to deny a minor's petition based on her failure to obtain parental consent. Premised upon these conclusions, the Court vacate the order of the Superior Court, which affirmed the order of the trial court. View "In the Interest of Jane Doe" on Justia Law

The Supreme Court granted review of this case to consider whether a cause of action for negligent infliction of emotional distress (NIED) exists where the emotional distress results from a "negligent breach of a contractual or fiduciary duty," absent physical impact or injury. After review of the development of the tort of NIED under Pennsylvania law and that of other states, the Court concluded that it was appropriate to extend liability for the infliction of emotional distress to a limited "species" of cases. Specifically, the Court suggested that NIED was not available in "garden-variety breach of contractual or fiduciary duty cases," but only in those cases where there exists a special relationship where it is foreseeable that a breach of the relevant duty would result in emotional harm so extreme that a reasonable person should not be expected to endure the resulting distress. The Court further concluded that recovery for NIED claims does not require a physical impact. View "Toney v. Chester Co. Hosp." on Justia Law

In 2001, Appellant Daniel Goodson was involved in a car accident. His insurance company paid $6,300 for the loss to the bank which still held title to the Appellant's car; Appellant received $135. Appellant, dissatisfied with his "meager" share of the insurance proceeds, presented a forged check for $6,300 to his bank with which to open a new account. The bank permitted Appellant to withdraw several thousand dollars before learning that the check was forged. The insurance company confirmed that it had not paid Appellant $6,300. Appellant paid back all the money he had withdrawn, but the State still pressed charges for forgery, insurance fraud and theft. Defendant challenged his sentence and conviction, arguing that he was not guilty of insurance fraud, and that his sentence was accordingly unreasonable. Finding that the trial court erred in convicting Appellant on insurance fraud charges, the Supreme Court remanded the case for resentencing based on forgery and theft. View "Pennsylvania v. Goodson" on Justia Law

In a consolidated appeal, the Commonwealth's Department of Revenue appealed the Commonwealth Court's decisions which held Appellees Northeastern Pennsylvania Imaging Center and Medical Associates of the Lehigh Valley P.C.'s MRI and PET/CT systems were not tangible personal property subject to sales tax under the Tax Reform Code of 1971 because they were part of real estate structures. Finding that the preparation for the installation of the systems and the special way the systems were "annexed" to the buildings in which they were placed, the Commonwealth Court concluded the systems were not tangible personal property subject to the tax but parts to the realty. The Department appealed both decisions. Upon review of the applicable sections of the Tax Code, the Supreme Court found that the equipment was subject to sales tax, and reversed the Commonwealth Court’s decision. View "NE Pa. Imaging Center v. Pennsylvania" on Justia Law

Appellant Abraham Sanchez, Jr. appealed his death sentence, raising eight claims of trial court error regarding aspects of the guilt and penalty phases of his trial, including a challenge to the timing and the use of the jury in adjudicating his claim of death penalty ineligibility under "Atkins v. Virginia," 536 U.S. 304 (2002). Appellant challenged the sufficiency of the evidence presented against him at trial, and sought an acquittal. Upon careful consideration of Appellant's arguments on appeal, the Supreme Court found the evidence was sufficient to convict him and to support they jury's death sentence. The Court found that Appellant was not entitled to an acquittal, and affirmed his conviction. View "Pennsylvania v. Sanchez" on Justia Law

Appellant David Ramtahal appealed his death sentence following his first-degree murder, conspiracy, possession of an instrument of crime and robbery convictions. On appeal to the Supreme Court, Appellant argued that: (1) the evidence was insufficient to convict him of first-degree murder; (2) the verdict was contrary to the weight of the evidence; (3) the trial court abused its discretion in limiting cross-examination of a prosecution witness; and (4) a new penalty hearing is warranted because the jury failed to specify what considerations prompted it to find the mitigating circumstance codified by law. Finding that None of Appellants claims merited relief, the Supreme Court found that Appellant's sentence was supported by sufficient evidence, including the aggravating factors determined by the jury. Accordingly, the Court affirmed Appellant's death sentence. View "Pennsylvania v. Ramtahal" on Justia Law

Appellant Brenda Jones was involved in an automobile accident with another driver that caused damage to her vehicle. Appellant's insurance policy with Nationwide Property and Casualty Company (Nationwide) included collision coverage for the vehicle involved, subject to a $500 deductible. The policy also provided Nationwide with the right of subrogation. Nationwide paid Appellant for all damage to the vehicle, reduced by the $500 deductible. Nationwide then filed a subrogation claim against the other driver and recovered under the other driver's liability coverage. The recovery, while in excess of Appellant's deductible, was only ninety percent of the amount Nationwide paid Appellant under the collision coverage policy. Nationwide paid Jones a pro rata share of the subrogation award by reimbursing her for ninety percent of her deductible, which amounted to $450. Appellant filed a class action against Nationwide claiming that Nationwide's uniform practice of pro rating reimbursements of deductibles violated the "made whole" doctrine. All claims were based upon Appellant's conclusion that Nationwide should have reimbursed her for her entire $500 deductible, despite the provision in the policy granting Nationwide subrogation rights. Appellant also sought injunctive relief to stop Nationwide's practice of pro rata deductible reimbursement. The Supreme Court concluded that the "made whole" doctrine did not apply to the collision coverage at issue in this case, the Court affirmed the dismissal of Appellant's class action. View "Jones v. Nationwide Property & Casualty Ins. Co." on Justia Law

Appellant Kia Motors America, Inc. unsuccessfully defended a class action lawsuit for breach of express warranty. It appealed a superior court's decision to affirm certification of the class by the trial court, and the amount of damages and litigation costs awarded to the class. Costs included a significant legal fee, entered pursuant to the Magnuson-Moss Warranty Improvement Act (MMWA). Appellee Shamell Samuel-Bassett, on behalf of herself and others similarly situated filed this class action lawsuit in January 2001, alleging that her Kia had an unsafe manufacturing defect in the braking system. In 2005, a jury rendered a verdict in favor of the class for breach of express warranty, and awarded damages in the amount of $600 per class member. The court molded the verdict to account for the 9,402 class members to which the parties had stipulated and recorded a $5.6 million verdict. Represented by new counsel, Kia filed an unsuccessful post-trial motion for judgment notwithstanding the verdict, or for a new trial. The issues on appeal to the Supreme Court were: (1) whether the class was properly certified; (2) whether evidence was sufficient to support the jury’s verdict and whether the verdict was against the weight of the evidence; (3) whether the jury’s verdict was properly molded to account for the 9,402 members of the class; (4) whether the trial court had authority to award attorneys’ fees after Bassett entered judgment on the class verdict; and (5) whether the risk multiplier was properly applied to an award of counsel fees under the MMWA. The Supreme Court affirmed in part, and reversed in part, the trial court's decision. The Court reversed the trial court to the extent that its order provided for enhancement of the attorneys' fees award beyond the amount permitted in the MMWA. View "Samuel-Bassett v. Kia Motors America, Inc." on Justia Law

The issue at the heart of this appeal involved whether the superior court interpreted and applied section 385 of the Second Restatement of Torts, which relates to the liability of a contractor or employee who creates a dangerous condition on land on behalf of the land's possessor. Appellee PA Partners, LP sold its steel plant to First Mississippi Steel, Inc. (FMS) in a "turn-key" transaction. FMS employees were operating one of the furnaces when a burn-through and series of steam explosions occurred. During the incident, hot steel fragments and parts of the plant structure fell onto the pouring platform and struck them. One employee was fatally injured and the other survived with scarring and disfigurement. Paula Livingston Gresik (the decedent's widow) and Joseph Beltowski (the injured employee) and his wife sued multiple parties, including PA Partners for damages arising out of the accident. Several years of litigation ensued and the court of common pleas dismissed some of the claims on preliminary objections. Eventually PA Partners remained as the only defendant in the suit. After further pleadings and discovery, the court granted PA Partners' motion for summary judgment on the sole remaining cause of action. The employees appealed to the superior court, maintaining that the court of common pleas failed to recognize that PA Partners could be held liable under a theory of negligent construction described in Section 385 of the Second Restatement of Torts. Upon review, the Supreme Court found that Section 385 did not provide a basis to hold PA Partners liable for damages ensuing from the accident. Accordingly, the Court held that the employees did not demonstrate that the court of common pleas erred in sustaining PA Partners' demurrer. View "Gresik v. PA Partners, LP" on Justia Law