Justia Pennsylvania Supreme Court Opinion Summaries

Appellee Raymond Haun was convicted on multiple sexual offenses for which he received a 27 to 97 year sentence in prison. Approximately one year after he was convicted, Appellee sought relief under the PCRA, arguing his trial attorney failed to contest his sentence despite his explicit request for counsel to do so. After testifying to the court regarding his wish to appeal, on cross-examination, the Commonwealth set out to elicit an admission that Appellee had committed the criminal acts for which he was convicted. The PCRA court overruled an objection to the line of questioning. Appellee then responded that he did, in fact, commit the offenses. Furthermore, he acknowledged that he previously admitted his guilt during the presentence investigation, at sentencing and in the assessment process required under Megan's Law. When asked why he wished to appeal his sentence, Appellee responded that he believed the length of his sentence was unfair. The issue before the Supreme Court was whether Appellee's confession of guilt foreclosed his access to judicial review under the Post Conviction Relief Act. The Commonwealth asked the Supreme Court to revisit its holding in "Commonwealth v. Lantzy" (735 A.2d 564 (1999)) and adopt the superior court's decision which "Lantzy" reversed. "In its brief, the Commonwealth has provided [the Court] with nothing to suggest that [the Court] was wrong in Lantzy... [the Court declined] to effectively overrule [its] decision based on a presentation which refuses to come to terms with [its] opinion's governing rationale." The Court held that a concession of guilt did not per se foreclose prisoner access to the PCRA. View "Pennsylvania v. Haun" on Justia Law

Appellant Shawn Walker appealed the dismissal of his motion for a new trial. In 1991, Appellant forcibly entered the home of his former girlfriend, shot and killed a man sleeping on the couch, and shot and permanently disabled the girlfriend. After finding two aggravating factors, the jury convicted Appellant of first degree murder and sentenced him to death. Appellant filed a pro se PCRA petition, raising numerous issues on appeal. Among them, Appellant claimed he received ineffective assistance of counsel because his trial counsel allegedly failed to present specific mitigation evidence. Upon careful review of the trial court and PCRA court records, the Supreme Court concluded that Appellant failed to establish that any of his claims entitled him to a new trial. Accordingly, the Court affirmed Appellant's conviction and sentence. View "Pennsylvania v. Walker" on Justia Law

Defendant Orlando Masionet was charged with the 1982 stabbing death of Jorge Figueroa. A local gang member testified against other members, including Defendant. One member received the death penalty; two others received life sentences. Defendant eluded capture for approximately ten years following the stabbing. Authorities sought help from the television show "America's Most Wanted" to help locate Defendant. He was eventually found in Puerto Rico and extradited to Pennsylvania to stand trial. The Commonwealth's theory of the case was that Mr. Figueroa was killed to prevent him from cooperating with police regarding a robbery-homicide perpetrated two weeks earlier, and Defendant played a part in both the robbery-homicide and death of Mr. Figueroa. Defendant was ultimately convicted of first-degree murder and related offenses. The jury found four aggravating circumstances and no mitigating circumstances for which he was sentenced to death. Defendant argued on appeal to the Supreme Court that the evidence presented at trial was insufficient to support his conviction in both matters. Upon careful review of the trial court record, the Supreme Court found the evidence sufficient to support Defendant's conviction, and affirmed his death sentence. View "Pennsylvania v. Masionet" on Justia Law

In 2006, Developer-Appellee 500 James Hance Court, LP entered into a construction management agreement with Contractor Gorman Construction Company, Inc., pertaining to the erection of a building at 500 James Hance Court, situated within the Oaklands Corporate Center in Exton, Chester County. According to the agreement, the contemplated, 68,000-square-foot structure was to be used as an elementary charter school, and the project was denominated "Collegium Charter School." Soon after the lease and related contracts were executed, the Bureau of Labor Law Compliance notified the School that it was investigating the project to determine whether prevailing wages were required. In this regard, the Bureau explained that charter school construction was treated the same as a traditional school project (re: public works project) for prevailing wage purposes. If the project's phases could be bifurcated, both the school and Appellee would be responsible. The issue between the parties centered on who was ultimately responsible for compliance with the prevailing wage law: the contractor or the school. The Commonwealth Court had found no evidence that the charter school had any role in determining space and performance goals for the project, and therefore the school was responsible for compliance. But upon review, the Supreme Court concluded that the Board’s determination that the lease was a disguised construction contract for the building as a whole, was based on legal error and essential findings which lacked substantial evidentiary support. Facially, the project was rationally divisible according to major phases of shell and fit-out construction. As to the shell, Appellees established the private character of the funding. Furthermore, in terms of economic reality, Appellees presented a prima facie case that Developer's only relationship with the School was per a bona fide pre-development lease. The Bureau failed to go forward with sufficient evidence to the contrary to overcome this prima facie case, and as such, affirmed the Commonwealth Court. View "500 James Hance Ct. v. Pa. Prevailing Wage Appeals Bd." on Justia Law

The International Association of Firefighters, Local 293, AFL-CIO (Union) is the exclusive bargaining representative of a unit of firefighters and other personnel employed by the City of Erie (City). While the City and the Union negotiated several previous collective bargaining agreements, the agreement at issue in this appeal was for the period from January 1, 2005 to December 31, 2007. The issue before the Court was whether the City committed an unfair labor practice when it unilaterally eliminated firefighter pension benefits which were found to be legal, without first collectively bargaining with the firefighters' representative. The Collective Bargaining by Policemen and Firemen Act, (Act 111), by its express terms, requires negotiation over the modification or elimination of pension benefits. Upon review, the Supreme Court found no applicable exception to this statutory mandate. Thus, the Court reversed the order of the Commonwealth Court which held to the contrary. View "City of Erie v. Pa. Labor Relations Board" on Justia Law

The issue before the Supreme Court pertained to the Surface Mining Conservation and Reclamation Act and whether it preempted a provision in a local zoning ordinance that established a setback for mining activities from all residential structures. The zoning ordinance at issue, which was enacted by Adams Township in Cambria County after the effective date of the Surface Mining Act, permits mining activities in a district known as the Conservancy (S) District only by special exception. Hoffman Mining Company, Inc. (Hoffman Mining) sought to mine for coal on a 182.1-acre tract of land within the Adams Township Conservancy (S) District adjacent to the Village of Mine 42. Hoffman Mining requested a special exception mine which was denied by the Zoning Board. Hoffman Mining appealed to the Commonwealth Court, which affirmed the Zoning Board's denial. Upon review, the Supreme Court found that with enactment of the Surface Mining Act, the General Assembly did not expressly or impliedly preempt a local zoning ordinance that imposes a residential setback from mining activities. The Court did "not discern an intent of the General Assembly to completely deprive local zoning authorities of their MPC-enabled authority and responsibility for land use management and planning as applied to the location and siting of surface mining in their municipalities." Accordingly, the Court affirmed the order of the Commonwealth Court. View "Hoffman Mining Co., v. Zoning Hearing Board of Adams Twp." on Justia Law

The issue before the Supreme Court was a court order that directed Appellant the Pennsylvania Department of Corrections (DOC) to select and pay for the services of a qualified professional to provide counseling to an incarcerated parent who sough visitation with his child. Resolution of the case was dependent upon the intended scope of section 5303 of Chapter 53 of the Domestic Relations Code relating to custody. "D.R.C, Sr." was serving time for first-degree murder. "J.A.Z.," the mother and custodial guardian "steadfastly opposed" prison visits for her son. Instead, she requested that visits be postponed until the son reached a sufficiently mature age and could make his own informed decision about visiting his father. A trial court denied D.R.C.'s request for visitation, which was timely appealed. On remand, the trial court ordered D.R.C. to present evidence that he was no longer a "grave threat of harm" to his son. This hearing was followed with a telephonic hearing in which the mother, D.R.C. and a licensed psychologist from the DOC testified. The court dismissed D.R.C.'s petition premised on language of the applicable legal standard precluded it from awarding visitation because D.R.C. never received the statutory-mandated counseling. On appeal, the Superior Court found that the trial court erred by not appointing a qualified professional to perform the counseling. The DOC intervened to challenge the trial court's directive to appoint the counselor. The court ultimately denied D.R.C.'s and the DOC's motions. Upon review, the Supreme Court concluded that the legal authority relied on by the trial court was misplaced: "we find the counseling required by [statute] is not a prerequisite to a court's engaging in its evaluation of a child's best interest in the context of a request for prison visits." Accordingly, the Court reversed and remanded the case back to the trial court to conduct a hearing on D.R.C.'s request for prison visitation in an "expeditious manner" without resort to the application of the statute. View "D.R.C., Sr. v. J.A.Z." on Justia Law

In the 1990s, Appellee Stephen Rambler mailed letters in an attempt to extort money from approximately thirty individuals by threatening to reveal certain sexually explicit correspondence if they did not pay him. Based on this conduct, Appellee was charged with violating federal law by mailing "threatening communications." Nearly ten years later, in November 2005, Appellee was elected mayor of Wrightsville, York County. He assumed office in January 2006. Two months later, the Commonwealth filed a complaint in quo warranto seeking to remove Appellee from office pursuant to Article II, Section 7 of the Pennsylvania Constitution. The Commonwealth alleged that the federal offense constituted an "infamous crime" in Pennsylvania, and requested an order declaring Appellee unqualified for his mayoral office. The common pleas court ultimately issued an opinion and order in favor of the Commonwealth, removing Appellee from office, and disqualifying him from holding any office of trust or profit in Pennsylvania. Appellee appealed, claiming that his federal extortion conviction did not qualify as an infamous crime because his conviction only carried a maximum sentence of two years which is comparable to a misdemeanor sentence in state court. The Superior Court reversed. The Supreme Court found in its review that "Appellee sought to reap dishonest gain… This type of behavior is, quite obviously, 'inconsistent with commonly accepted principles of honesty and decency,' and is, moreover, akin to 'swindling, cheating, and other crimes of a kindred nature.'" The Court reversed the Superior Court and remanded the case for further proceedings. View "Pennsylvania v. Rambler" on Justia Law

The Pennsylvania Attorney General appealed a superior court's order that reversed the Philadelphia County Orphans' Court order which held Wachovia Bank was not entitled to receive commissions from the principal of an estate for its trust administration services. The Decedent Anna Fridenberg passed away in 1940, leaving the residue of her estate and other property to a trust for five named individuals no longer living. The remainder of the net income was to be given to the Jewish Hospital Association of Philadelphia. Wachovia Bank was the trustee to the Friedenberg estate and filed the annual accounting of the estate. The accounting also included requests for commissions to be paid out of principal for Wachovia and one of the individual successors. The Attorney General objected to this request, arguing the law in effect at the time the trust was created prevented parties who served as both executors and trustees under a will from receiving more than one commission from principal. The Attorney General noted Wachovia's corporate predecessor already received a commission from principal for its services; therefore, Wachovia was not entitled to another commission from principal. The Orphans' court sustained the objection, holding the law at the time the trust was created barred more than one commission from principal, despite subsequent changes in the law that now allow more than one commission. Wachovia appealed, and the Superior Court reversed, holding that the numerous legislative enactments over the past half-century permitting more than one commission for previously established trusts were constitutionally valid. Upon review, the Supreme Court agreed with the Superior Court's ruling and affirmed that court's decision. View "In re: Estate of Fridenberg" on Justia Law

The issue on appeal to the Supreme Court in this case pertained to the extent to which the federal Employee Retirement Income Security Act (ERISA) preempted the Pennsylvania Probate, Estates and Fiduciaries Code, 20 Pa.C.S. 6111.2. The Decedent Paul Sauers, III obtained a $40,000 life insurance policy in 1997 from the Hartford Life Insurance Company pursuant to a employee group benefit plan which was subject to ERISA. At the time of his death, Decedent's beneficiaries were his ex-spouse and his nephew as contingent beneficiary. William F. Sauers, administrator of Decedent’s estate, filed in the Orphans’ Court of York County a petition for rule to show cause why primary beneficiary ex-Spouse should not have surrendered to the Contingent Beneficiary all interest in the proceeds of the insurance policy pursuant to 20 Pa.C.S. 6111.2. The ex-spouse objected and filed a motion to dismiss the petition for rule to show cause, arguing that regardless of any Pennsylvania statute to the contrary, ERISA mandated taht the proceeds of the policy be paid to her as the primary beneficiary of the policy. Upon review, the Supreme Court held that while an estate may properly bring a cause of action on behalf of a contingent beneficiary to a life insurance policy in a county orphans’ court seeking the proper distribution of assets, ultimately, ERISA preempts Section 6111.2 of the Probate Code. To the extent the en banc panel of the Superior Court held otherwise, the Court reversed and remanded this appeal to that court for further proceedings. View "In Re: Estate of Sauers" on Justia Law