Justia Pennsylvania Supreme Court Opinion Summaries

At issue before the Supreme Court was whether it was a violation of public policy to exclude from underinsured motorist coverage (UIM) a claim by an individual eligible for workers' compensation benefits. Appellant Frank Heller was severely injured from an automobile accident that happened during the course of his employment as a police officer for Sugarcreek Borough. Workers' Compensation covered his medical expenses and two-thirds of his salary. The Borough paid the remainder of Appellant's salary. Appellant's losses and damages far exceeded the policy limit from the tortfeasor's insurance carrier. Accordingly, Appellant notified his insurer of a potential UIM claim and sought UIM benefits from the Borough pursuant to a policy issued by the Pennsylvania League of Cities and Municipalities. Ultimately, Appellant's claim was denied. Upon review, the Supreme Court concluded that an exclusion in Appellant's workers' compensation policy violated public policy and was therefore unenforceable. The Court reversed the Commonwealth Court which held that the policy considerations favored the insurer: "Invalidating the workers' compensation exclusion would not force [the UIM insurer] to underwrite an unknown risk for which it did not receive compensation. The Borough voluntarily elected to purchase optional UIM coverage. .. [W]e find [Appellant's] assertion that the Borough purchased illusory coverage persuasive… the vast majority of all UIM claims likely will be made by Borough employees who are eligible for workers' compensation. The subject exclusion operates to deny UIM benefits to anyone who is eligible for workers' compensation." View "Heller v. Pa. League of Cities and Municipalities" on Justia Law

In this discretionary appeal, the Supreme Court reviewed the lower courts' application of the "totality of the circumstances" test for the existence of probable cause necessary to issue a search warrant as set forth by the U.S. Supreme Court in "Illinois v. Gates" and adopted by Pennsylvania in "Commonwealth v. Gray." Specifically, the Court questioned whether the lower courts properly applied the test in determining whether a search warrant was infirm because the affidavit of probable cause failed to expressly attest to the veracity, reliability and basis of knowledge of a confidential informant. Because the totality of the circumstances applied by the trial court in Appellee Steven Clark's case included a factual recitation describing a successful controlled buy of narcotics that corroborated the affiant's averment that the informant was reliable, and because that recitation demonstrated a fair probability that narcotics would be found in the location for which the warrant was sought, the Court determined that the warrant was supported by probable cause. The Court found that the appellate court's suppression of evidence was contrary to its holding here, reversed that court, and remanded the case to the trial court for further proceedings consistent with this opinion. View "Pennsylvania v. Clark" on Justia Law

Appellant Terry Chamberlain appealed the death sentence imposed on him after a jury convicted him of two counts of first-degree murder, burglary and possessing "an instrument of crime" in 1994. On direct appeal, the Supreme Court held that the trial court abused its discretion in denying a pretrial motion for a continuance to allow Appellant to obtain DNA testing of certain blood evidence. The case was remanded for the trial court to allow Appellant to do the testing. The trial court completed proceedings on remand, and the case went back to the Supreme Court for its consideration on the remaining claims in Appellant's appeal. Upon review of those claims, the Court affirmed Appellant's death sentence. View "Pennsylvania v. Chamberlain" on Justia Law

The Supreme Court considered the effect of a pro se notice of appeal which was forwarded to the superior court by a counseled criminal defendant, where counsel, who was not made aware of the pro se notice, subsequently filed a timely post-sentence motion which was denied by the trial court, and then a second timely notice of appeal. In this case, the superior court administratively quashed the counseled-appeal as duplicative, then quashed Appellee Michael Cooper's pro se appeal as premature and void. Yet the court also remanded the case to the trial court for additional review of the counseled post-sentence motion. Upon review, the Supreme Court held that the superior court erred in quashing the appeal and remanding the counseled post-sentencing motion. Therefore, the Court vacated the order and remanded the case back to the superior court for consideration of the merits of Appellee's direct appeal. View "Pennsylvania v. Cooper" on Justia Law

Appellants the Piper Group filed a constitutional challenge to a 1996 zoning ordinance enacted by Bedminster Township. In support of this challenge, Piper relied on an opinion from the Supreme Court that had been announced six days earlier pertaining to the same ordinance, "C&M Developers, Inc. v. Bedminster Twp. Hearing Bd." In "C&M," the Court invalidated the Township’s ordinance because it contained certain requirements that unconstitutionally restricted a landowner’s development rights. Relying heavily on C&M, Piper identified those same constitutional defects and sought permission to develop its land at a significantly higher density than would have been permissible under the invalidated ordinance. The Board of Supervisors, the trial court, and the Commonwealth Court all rejected Piper’s proposed cure to the unconstitutionality and held that Piper could develop its land in accordance with the Township’s alternative amended ordinance which cured the constitutional defects in the 1996 ordinance as identified in C&M and allowed increased development, but not to the extent requested by Piper. On appeal to the Supreme Court, Piper argued that the lower courts improperly denied Piper the full relief it requested. Specifically, Piper argued that the decisions violated the Municipalities Planning Code (“MPC”) and the “pending ordinance doctrine” as set forth in "Casey v. Zoning Hearing Bd. of Warwick Twp.," (328 A.2d 464 (Pa. 1974)) and its progeny. The Court disagreed and therefore affirmed the lower courts' decisions. View "Piper Group, Inc. v. Bedminster Twp." on Justia Law

n this appeal, the issue before the Supreme Court was whether the mere offer of an automobile ride to a child constituted an attempt to “lure” the child under Section 2910 of Pennsylvania’s Criminal Code, entitled “Luring a child into a motor vehicle or structure.” Appellant was charged with four counts of harassment, stalking, and attempted luring of a child into a motor vehicle for offering two neighborhood boys a ride to school in Appellant's own neighborhood. He had seen the children in the neighborhood, and offered them short rides to school or to the store. The children declined, and Appellant made no further attempt to "help." Appellant was acquitted of the charged at a bench trial because the judge "expressly stated she found no evidence that Appellant had any intent to harm the children, and that she believed 'the circumstances show no reason to believe that this defendant had any evil or improper intent in doing what he did.'” However, on the sole basis of Appellant’s offer of the rides, she convicted him on all four counts of attempted luring. The trial court found that “[Appellant’s] offer of a ride to the victims is sufficient to constitute an attempt to ‘lure.’” The trial court subsequently sentenced Appellant to 18 months’ probation. As an automatic result of his convictions, Appellant was statutorily mandated to register for ten years as a sex offender under Megan’s Law. Appellant filed an appeal to the Superior Court, arguing that the evidence was insufficient as a matter of law to sustain his conviction, because his offer of a ride to the children, by itself, did not constitute a “lure” or an attempt to “lure,” given that he did not offer the children any enticement to get into his car, nor did he command or otherwise threaten them. Appellant also argued that he had no ill intent in offering the children a ride, but, rather, was merely acting as a “disabled Good Samaritan.” After careful review, the Supreme Court concluded that an attempt to “lure” does not include the action of simply extending an offer of an automobile ride to a child, when it is unaccompanied by any other enticement or inducement for the child to enter the motor vehicle. Consequently, the Court reversed Appellant's conviction for attempted luring. View "Pennsylvania v. Hart" on Justia Law

Kelsey Lauren Miller was the sole minor child of Appellant Kristi George (Mother) and Wesley Miller (Father). After the parents divorced, they shared joint legal custody of Kelsey until the Father died in April 2007. Although the Father died intestate, he had designated Kelsey as the sole beneficiary of his Federal Employee Group Life Insurance Policy valued at $356,000. The Father’s sister, Appellee Pamela Wahal, served as the administratrix of his estate. In late 2007, Appellee, as the "next friend" of Kelsey, filed a petition for the appointment of a limited guardian of Kelsey’s estate, asserting that Kelsey lacked the "necessary knowledge and maturity to manage the funds to which she is entitled following her father’s death." Appellee proposed that her attorney be appointed to serve as the limited guardian. The Mother filed a response to Appellee’s petition, denying the need for the appointment of a limited guardian of Kelsey’s estate. The issue presented on appeal to the Supreme Court in this case was whether a parent has legal standing to challenge the appointment of a guardian for her child’s estate. Upon review, the Court held that a parent does have standing. The Court reversed the Superior Court's order appointing a trustee, and remanded the case for further proceedings. View "In Re: Kelsey Miller" on Justia Law

Appellant Michael Travaglia appealed his death sentence imposed by the Westmoreland County Court of Common Pleas following a penalty hearing held pursuant to a grant of federal habeas corpus relief. Appellant was convicted in the shooting death of an Apollo police officer in 1980. Prior to the officer's homicide, state police received information indicating that Appellant was involved in a number of armed robberies and killings in Pittsburgh and surrounding counties. Appellant would later give a statement to police implicating himself in the killing of the officer and several others. Following the denial of his post-sentence motions Appellant appealed to the Supreme Court where he raised eighteen alleged errors in his penalty hearing. The Supreme Court took each issue in turn and ultimately affirmed Appellant's death sentence. View "Pennsylvania v. Travaglia" on Justia Law

Sean Pearce was bicycling along a road when he collided with a construction barrel and fell into the road. At least two vehicles, one driven by Appellee Gregory Wisneski, subsequently fatally struck Pearce. Appellee later admitted driving along the road when, initially thinking he hit a speed bump, he looked in his mirror and saw a body in the road. Appellee did not stop at the scene. The Commonwealth charged Appellee with failing to stop at an accident, failing to comply with a duty to give information and render aid, and failing to immediately notify the police. Appellee filed a habeas petition seeking dismissal of the charges, arguing the Commonwealth could not prove Pearce was alive when Appellee struck him. The trial court concluded that the statutes required the victim to be alive at the time of the accident, reasoning that "once a victim of an accident is dead, the accident concludes that the statutes cannot apply to vehicles that later come upon the scene." A divided Superior Court affirmed the trial court's dismissal of the information against Appellee. Upon review, the Supreme Court found that "a person does not turn into mere property upon their death, certainly not for purposes of a driver's obligations under the Vehicle Code. We find, therefore, the term 'resulting in injury' must include causing harm or damage to the body of a human, whether deceased or not. To find otherwise would defeat the legislative scheme, and would be offensive to our notions of the value of the person." The Court reversed the Superior Court and remanded the case for further proceedings. View "Pennsylvania v. Wisneski" on Justia Law

The issue central to this case was whether Appellee George Banks was competent to be executed. Appellee used a semi-automatic rifle to murder thirteen people and seriously wounded a fourteenth in an early morning shooting spree in 1982. Five of the victims were Appellee's children, and four were Appellee's former or then-current girlfriends. In 2004, the Supreme Court ordered the trial court to determine whether Appellee had the capacity to initiate clemency proceedings or to designate someone to initiate them on his behalf. "To say that [the Court's] direction for expedition went unheeded by [the trial court judge] would be an understatement." Clemency proceedings were delayed by federal counsel seeking to burden the Commonwealth's ability to have its mental health experts examine Appellee in order to prepare a case in rebuttal against counsel's claim that Appellee had become insane. The Court concluded that "the competency question [was] important, but narrow, and it should have been resolved sooner." Following the Court's review of the competency determination rendered by the trial court, the Court concluded that Appellee was incompetent to be executed under the standards set forth in Pennsylvania case law. "It appear[ed] that [Appellee was] in a different place mentally than he was nearly thirty years ago when he committed his crimes and when he was tried." View "Pennsylvania v. Banks" on Justia Law