Justia Pennsylvania Supreme Court Opinion Summaries

In 2005, Robert Sample was found face down on a Philadelphia city sidewalk, dead from multiple gunshot wounds to his head and neck. In canvassing the area for witnesses, detectives knocked on the door of a third-floor apartment in a nearby high-rise. Jamilla and Dominique Everett opened the door. After obtaining permission to enter the apartment, detectives found Jamilla's children, Dominique's boyfriend Khalif Alston and Appellee Ernest Cannon asleep inside. Everyone inside the apartment denied any knowledge of the shooting but agreed to accompany the police to the station for further questioning. Later on the day of the murder, the Everetts consented to a search of their apartment. Police recovered a semiautomatic handgun from inside the toilet tank. Everyone inside the apartment that day was questioned again. When detectives interviewed Mr. Alston, he confessed to his role in the crime and implicated Appellee. Following the consolidation of their cases, a jury tried both men. Since Appellee and Mr. Alston were being tried together, the statement that Mr. Alston gave to the police on the day of the murder was redacted by substituting the phrase "the other guy" for any reference to Appellee by name. The prosecution "slipped" and named Appellee in his opening statement as he recounted the events on the date of the murder. At the conclusion of the prosecutor's opening, Appellee objected and moved for a mistrial, claiming that the prosecutor "broke the redaction." The trial court gave the jury an immediate cautionary instruction. The jury returned a verdict against Appellee, convicting him of first-degree murder, robbery, conspiracy and carrying a firearm. The trial court then sentenced Appellee to life in prison for the murder conviction, with concurrent sentences for the other charges. On appeal to the Superior Court, Appellee successfully argued that he was entitled to a new trial because of the prosecutor's slip up during his opening statement. The Commonwealth appealed, arguing that the trial judge's cautionary instruction was sufficient to support Appellee's conviction. Upon review, the Supreme Court found that the trial court gave "direct, unequivocal and strong" cautionary instructions, repeatedly detailing the proper manner of weighing the evidence. "The trial court, which is in the best position to assess whether any prejudice can be cured, determined that the prosecutor's comment did not justify a mistrial." Accordingly, the Court reversed the judgment of the Superior Court and reinstated the verdict and sentences of the trial court. View "Pennsylvania. v. Cannon" on Justia Law

In this appeal, the Supreme Court consolidated four cases to decide whether adopted children whose adoptions were procured through a state-licensed private agency in the 1990s were eligible to receive adoption assistance subsidies retroactive to the dates of the children’s adoptions and prospectively through their eighteenth birthdays. The children’s attorneys successfully argued to the Commonwealth Court that the adopted children were eligible for subsidies pursuant to the Pennsylvania Adoption Opportunities Act (AOA). The Department of Public Welfare (DPW) appealed the Commonwealth Court’s decision. Upon review of the underlying cases, the Supreme Court held that "adoption subsidies were never intended to be windfalls for adoptive parents." The Court reversed the lower court’s decision and reinstated the DPW's ruling with respect to the appellants in the consolidated cases. View "Laird v. Penna. Dep't. of Public Welfare" on Justia Law

Appellant Robert Petty is sole owner of Co-Appellant R.G. Petty Masonry. Appellants contracted with Respondent Blue Cross of Northeastern Pennsylvania (Blue Cross), a nonprofit hospital corporation that provides health insurance coverage for its employees. Appellants are covered under the group policy as subscribers. Appellants filed a four-count class action suit against Blue Cross, alleging that it violated the state Nonprofit Law by accumulating excessive profits and surplus well beyond the "incidental profit" permitted by statute. The second count alleged Blue Cross breached its contract with Appellants by violating the Nonprofit Law. The third count alleged Blue Cross owed appellants a fiduciary duty by virtue of their status as subscribers, and that duty was breached when it accrued the excess surplus. The fourth count requested an inspection of Blue Cross' business records. The trial court found Appellants lacked standing to challenge Blue Cross' alleged violations of the Nonprofit Law and dismissed the suit. The Commonwealth Court affirmed the trial court. Upon careful consideration of the briefs submitted by the parties in addition to the applicable legal authorities, the Supreme Court found that Appellants indeed lacked standing under the Nonprofit Law to challenge Blue Cross by their four-count complaint. Accordingly, the Court affirmed the lower courts' decisions and dismissed Appellants' case. View "Petty v. Hospital Service Assoc. of NE Penna." on Justia Law

Defendant Ralph Birdsong unsuccessfully appealed his sentence for murder, rape and assault. He was sentenced to death. In his appeal to the Supreme Court, he argued that the appellate court improperly denied his petition for post conviction relief. Defendant cited multiple errors at trial that entitled him to a reduction in his sentence or complete dismissal of the charges against him. The Supreme Court reviewed the record and found that Defendant was not entitled to relief. The Court affirmed the order of the lower courts denying Defendant's petition for post conviction relief.

The State appealed a Superior Court order that allowed Defendant Vincent Moto to expunge his criminal record. In 1987, Defendant was convicted of rape, deviate intercourse and conspiracy charges and was sentenced to a maximum twenty-four year sentence. Ten years into his sentence, DNA testing exonerated the Defendant. The State "nolle prossed" his case. In 2007, Defendant petitioned the court to expunge all records of his arrest, trial, conviction and sentence. The attorney who originally prosecuted the case opined that the DNA evidence did not necessarily exculpate Defendant because he was still present at the scene. Furthermore, the State would have retried Defendant except that the victim had moved out of state. The trial court ultimately denied Defendant's request to expunge his record. Upon review, the Supreme Court concluded that it was unable to agree with neither Defendant's assertions nor the Superior Court's determinations of trial court error. The trial court denied Defendant's petition to expunge based primarily on the strength of the original 1987 case against him, and the inability of DNA evidence to exonerate him. The Court therefore reversed the Superior Court, and reinstated the trial court's decision.

The Commonwealth Court declined to issue a writ of mandamus to Appellant Crozer Chester Medical Center (Crozer) in its attempt to force the Department of Labor and Industry (Department) to reimburse it for medical fees. Claimant William Radel suffered a work-related injury while lifting a bundle of rebar for his employer. The claimant underwent surgery at Crozer, and Crozer sent claimant's records and the bill to claimant's insurance company, Zurich North American Insurance (Zurich). Zurich did not pay, nor did it deny the claim. Crozer then turned to the State for reimbursement. The Department rejected the application as "premature," because Zurich's non-payment made an "outstanding issue of liability/compensability for the alleged injury." Crozer then petitioned the Commonwealth Court to force the Department to pay. The Supreme Court agreed that Crozer's application for reimbursement was premature. The Court found that Crozer did not try to resolve Zurich's nonpayment before petitioning the State or the Commonwealth Court. The Court affirmed the decision of the Department and the lower court, and dismissed Crozer's petition for a writ of mandamus.

Pennsylvania's current version of Megan's Law requires individuals convicted of kidnapping, indecent assault, or promoting prostitution to register for ten years following release from jail or probation. Persons convicted of two or more offenses subject to the ten-year registration must register for life. Allegheny County (the County) amended its code to add to the registration requirements: if a registrant moves to a "prohibited area" within the County, s/he will have 45 days to move out. Failure to move within the 45 days would constitute a separate offense. Appellee Charles Fross and several other parties were convicted sex offenders subjected to the County's new rule. They brought suit in federal court to challenge the new ordinance, arguing that the rule was preempted by the state Sentencing and Parole Codes, and asked the court to declare the ordinance invalid. The federal court certified the question of whether the County's ordinance was preempted by the Pennsylvania Prisons and Parole Code and/or by the Pennsylvania Sentencing Code to the Supreme Court. The County argued that the ordinance was a permissible exercise of its powers, and was valid. The Supreme Court found that the ordinance "impedes the accomplishments of the full objectives of the General Assembly, as expressed in the Sentencing and Parole Codes, and is . . . invalid pursuant to our conflict preemption doctrine."

Appellant Walnut Street Associates (WSA) provides insurance brokerage services and helps employers obtain health insurance for their employees. Appellee Brokerage Concepts, Inc. (BCI) is a third party administrator of employee benefit plans. Procacci retained BCI as administrator of its insurance plans, and BCI paid commissions to WSA based on premiums paid by Procacci. In 2005, Procacci requested BCI reduce its costs, but BCI would not meet Procacciâs proposal. Procacci then notified BCI that it would take its business elsewhere. BCI asked Procacci to reconsider, and in the process, disclosed to Procacci how much it paid to WSA as its broker. The amount was higher than Procacci believed WSA had been earning, but there was no dispute that BCIâs statements about WSAâs compensation were true. As a result of BCIâs letter, Procacci terminated its contract with WSA. WSA sued BCI alleging that BCI tortiously interfered with the WSA/Procacci contract by disclosing the amount of WSAâs compensation. BCI argued that it could not be liable for tortious interference because what it said was true, or otherwise justified and privileged. At trial, the jury found that BCI did interfere in the WSA/Procacci contract. BCI appealed, and the appellate court reversed the trial courtâs judgment. The appellate court adopted a section of the Restatement of Torts, which said that truth is a defense to a claim of tortious interference. WSA maintained that the Restatement was not applicable according to Pennsylvania law. The Supreme Court reviewed the case and adopted the Restatement defense that truth is a defense to claims of tortious interference with contractual relations. The Court affirmed the decision of the appellate court.

Appellee Ronald Gibson challenged his sentence for the shooting deaths of a police officer and a bystander during a failed robbery attempt at a bar in Philadelphia. After multiple remands, Appellee argued to the Supreme Court that he received ineffective assistance of counsel that resulted in prejudice against him at trial. The appellate court concluded that Appelleeâs counsel was âderelictâ by failing to adequately investigate life-history or mental health mitigation evidence. The court concluded, however, that the trial court should have resolved certain questions that arose from evidentiary discrepancies. The Supreme Court performed an exhaustive review of the evidence presented at trial. While not diminishing Appelleeâs troubles, the Court found that the mitigating evidence Appellee sought to enter at trial was not enough to overcome the aggravating factors introduced at trial or to overturn the juryâs verdict. The Court held that Appelleeâs claim for ineffective assistance of counsel to be unfounded, and it affirmed Appelleeâs conviction and sentence.

Appellee Edward Watts was convicted of first-degree murder and numerous other offenses in 2001 and sentenced to life imprisonment. He filed a timely direct appeal, but the Superior Court dismissed it for failing to include a docketing statement. Defense counsel was directed to certify that he had notified Appellee of the dismissal, but he never filed the required certification saying that he did so. Throughout 2002 and 2003, Appellee sought status updates on his appeal. In August, 2003, the Superior Court advised Appellee that his appeal had been dismissed. Within days of receiving that notice, Appellee filed a pro se Post Conviction Relief Act (PCRA) petition, seeking reinstatement of his appellate rights. The PCRA Court dismissed his claim, but the Superior Court reversed that decision. The Supreme Court was not persuaded by Appelleeâs argument that because he did not know (and had no way of knowing except through his attorney) that the appeal had been dismissed, he should be afforded an opportunity to have his petition heard. The Court reversed the Superior Courtâs decision, finding Appelleeâs petition was properly dismissed in the lower court for being untimely filed.