Justia Pennsylvania Supreme Court Opinion Summaries

The Commonwealth appealed a portion of a superior court order that reversed Appellee Daniel Sinnott's conviction for ethnic intimidation baed in insufficient evidence. Appellee got into a heated argument with his landlord/employer, hurling epithets and throwing things at the landlord and members of his family. Appellee was charged with simple assault, terroristic threats, ethnic intimidation, and possession of instruments of crime. He waived his right to a jury, and the trial court convicted him of all offenses, sentencing him to four to 23 months imprisonment for simple assault and a consecutive four years probation for terroristic threats; no further penalty was imposed. Appellee appealed, challenging the sufficiency of the evidence in support of his terroristic threats and ethnic intimidation convictions. The superior court affirmed the terroristic threats conviction, but reversed the conviction for ethnic intimidation, concluding the record failed to establish the landlord's ethnicity was the "primary basis" for appellee's behavior. In crediting appellee's contention that his conduct was solely motivated by anger with the landlord, the Supreme Court found that the superior court not only imposed a non-existing requirement that racial animus be the sole or primary motivator, but also failed to view the evidence of Appellee's repeated derogatory ethnic slurs in the light most favorable to the Commonwealth as the verdict winner. Accordingly, the Supreme Court reversed the portion of the superior court's order reversing appellee's ethnic intimidation conviction, and reinstate the judgment of sentence for that offense. In all other aspects, the order was affirmed. View "Pennsylvania v. Sinnott" on Justia Law

The issue on appeal before the Supreme Court in this case was whether expert testimony is required to convict a defendant of driving under the influence of a drug or combination of drugs when the drugs in question are prescription medications. Appellee Michelle Griffith was charged with DUI following an eyewitness' account of her driving in a "reckless and dangerous manner." Appellee failed field sobriety tests administered by law enforcement. Diazepam, Nordiazepam and "Soma 350" were detected in her blood which Appellee admitted to taking on the morning of the incident. At trial, two individuals testified: the eyewitness and the responding police officer. The trial court convicted Appellee and sentenced her to three months' imprisonment and a fine. Appellee appealed the conviction, arguing the evidence was not sufficient without testimony of an expert to establish the medications impaired her ability to drive safely. The superior court agreed an expert was needed and vacated Appellee's conviction. The Commonwealth appealed. The Supreme Court reversed the superior court, finding the evidence was sufficient to establish Appellee was under the influence of drugs to a degree that impaired her ability to drive. View "Pennsylvania v. Griffith" on Justia Law

In this discretionary appeal, the Supreme Court was asked to address whether the "regular use" exclusion in a personal automobile insurance police was valid to preclude payment of underinsured motorist benefits (UIM) to a police officer injured in the course of employment while operating his police vehicle for which the officer did not have an ability to obtain UIM coverage. Appellant Robert Williams was a Pennsylvania State Trooper seriously injured in an accident involving his police vehicle. At the time of the accident, Appellant maintained a personal automobile insurance policy with Government Employees Insurance Company (GEICO). He sought to recover UIM benefits from GEICO from the accident, but GEICO denied coverage citing the "regular use" exclusion contained in the policy. The trial court granted GEICO's motion to dismiss, and the Superior Court affirmed in an unpublished memorandum. Appellant argued on appeal that because of the special factual circumstances and challenges he faces as a state trooper, his insurer should have provided him with UIM coverage "despite the unambiguous policy exclusion because Pennsylvania has a strong public policy of protecting police officers and other first responders such that they are entitled to special treatment." Upon review, the Supreme Court concluded "Appellant's argument simply fails." The Court held that the trial and superior courts were correct in denying Appellant coverage under his UIM policy, and affirmed their decisions. View "Williams v. Government Employees Ins. Co." on Justia Law

In this capital case, Appellant Ronald Hanible appealed an order of the Court of Common Pleas of Philadelphia County (PCRA court) which denied without a hearing all guilt phase claims raised in his petition for post-conviction relief. Appellant was convicted on two counts of murder. Appellant did not testify on his own behalf or present any witnesses at trial. Instead, he urged the jury to reject the Commonwealth's key witness' testimony as unreliable. Appellant further argued to the jury that none of the physical evidence recovered by police implicated him in the crime. Following the penalty hearing, the jury found two aggravating circumstances and no mitigating circumstances. Accordingly, it returned a verdict of death. Appellant filed a pro se PCRA petition and was appointed counsel. The PCRA court granted a new penalty hearing based on evidence that Appellant's trial counsel failed to present available mitigating evidence. Appellant raised sixteen issues for review to the Supreme Court based on the PCRA's dismissal of his relief petition. The Supreme Court took each in turn, and ultimately affirmed the PCRA court's decision to deny Appellant the relief he requested. View "Pennsylvania v. Hanible" on Justia Law

Consolidating several appeals, the Supreme Court addressed the effect of a municipality's financial distress and recovery planning on an arbitration award agreed to pursuant to the Policemen and Firemen Collective Bargaining Act (Act). For approximately twenty years, the City of Scranton has been designated a distressed municipality under the Municipalities Financial Recovery Act. Pursuant to the Recovery Act, the City has its Commonwealth-mandated financial advisors who assist in creating a financial recovery plan (essentially a budget). In the most recent collective bargaining agreements between the City of Scranton and its Police and Firefighter Unions expired at the close of 2002. Negotiations as to future terms and work conditions for union members resulted in impasses. Accordingly, pursuant to the Act, arbitrators were selected to establish appropriate terms and conditions. Throughout the arbitrations, the City maintained that the arbitrators lacked legal authority to award relief impinging on the City's financial recovery plan. The City attempted to resist paying the ensuing award that resulted from the arbitration. The Commonwealth Court found that it was required to vacate the awards, holding that they did not conform to the City's Recovery Plan and would result in increased financial and operational burdens on an already distressed municipality. The Unions appealed to the Supreme Court. The Court focused on the distinction between the terms "arbitration award" and "arbitration settlement": the City argued that it was not mandated to pay "awards" but "settlements." The Supreme Court found the term "settlement" ambiguous, and the plain meaning could include the "award" given by the arbitrators in this case. Accordingly, the Court reversed the Commonwealth Court's order that the award negatively impacted the City's Recovery Plan. View "City of Scranton v. Firefighters Local Union" on Justia Law

At issue before the Supreme Court was whether an opinion rendered by a medical expert was sufficient to rebut the presumption of disease causation under the Pennsylvania Workers' Compensation Act. Joseph Kriebel worked for the City of Philadelphia as a firefighter from 1974 to 2003. He died in 2004 from liver disease caused by hepatitis C. His widow Appellant Patricia Kriebel, filed a claim petition under the Act in 2005, alleging that her husband contracted hepatitis C in the course of his employment. Appellant sought to raise the presumption of occupational exposure. In support of her claim, Appellant presented the testimony of her husband's treating physician. The City rebutted the presumption of disease causation with testimony of its own medical expert. Upon review, the Supreme Court held that an expert's opinion does not constitute substantial competent evidence where it is based on a series of assumptions that lack the necessary factual predicate. Since the medical opinions in this case were based on unfounded suppositions, they were legally insufficient to overcome the presumption of disease causation. The Supreme Court reversed the Commonwealth Court that held that the City overcame the presumption with its' medical expert's testimony, and reinstated the order of the superior court which held in favor of Appellant. View "City of Philadelphia v. Workers' Comp. Appeal Bd." on Justia Law

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