Justia Pennsylvania Supreme Court Opinion Summaries

Appellee Linda Reibenstein undisputedly brought her claims against Appellant Patrick Conaboy, M.D., after the two-year period had run, and the death certificate undisputedly and correctly noted the medical cause of Reibenstein’s decedent’s death. The trial court ruled that the phrase “cause of death” referred specifically and only to the direct medical cause of death. Accordingly, it granted summary judgment to Dr. Conaboy under Section 513(d) of the Medical Care Availability and Reduction of Error Act (“MCARE”). The Superior Court reversed, interpreting “cause of death” more broadly to encompass considerations associated with the manner of death (i.e., legal cause). The Pennsylvania Supreme Court held that MCARE’s tolling provision could not bear the breadth of that reading, and reversed. View "Reibenstein v. Barax" on Justia Law

The issue presented was one of first impression for the Pennsylvania Supreme Court: whether trial counsel was ineffective for failing to object to a jury instruction in which the judge analogized jurors’ application of the “proof beyond a reasonable doubt” standard to jurors’ hypothetical decision-making regarding surgery involving a “precious one.” Appellant Gerald Drummond was convicted and sentenced to two consecutive life sentences for the shooting deaths of Timothy Clark and Damien Holloway. Holloway had an on-again, off-again relationship with Drummond’s sister, Annie. It was alleged Drummond did not approve of the relationship. Gunshot evidence suggested Clark was killed execution-style by an assailant standing behind him while Clark knelt with his hands interlocked behind his head. Holloway was shot in the cheek; he died later from brain hemorrhaging. After review of the jury instructions, the Pennsylvania Supreme Court concluded the instructions were reasonably likely to cause a jury to apply a diminished standard of proof in criminal cases, thus posing significant risks to a defendant’s due process rights. Accordingly, the Court found arguable merit to Drummond’s ineffective assistance of counsel claim. However, because counsel could not be deemed ineffective for failing to anticipate a change in the law, it affirmed the Superior Court’s order affirming the denial of Drummond’s PCRA petition. View "Pennsylvania v. Drummond" on Justia Law

In late 2012, 16-year-old Shane McGuire and a group of his friends smashed pumpkins and stacked bricks on the doorstep of a home in McGuire’s neighborhood. The teens were still on the property when the homeowner, City of Pittsburgh Police Officer Colby Neidig, arrived home with his wife and children. McGuire watched the family’s reaction to the vandalism and then banged on the front door and ran away, accidentally tripping over his own brick boobytrap in the process. Neidig saw McGuire running, and gave chase, catching McGuire, knocking him to the ground and punching McGuire in the face. Neidig was not wearing his police uniform at the time, nor did he identify himself as a police officer. Neidig called 911 and restrained McGuire until Officer David Blatt, an on-duty City of Pittsburgh police officer, arrived. Two years later, McGuire filed a federal lawsuit against Neidig, Blatt, and the City of Pittsburgh, asserting excessive use of force in violation of 42 U.S.C. § 19833 and state law assault and battery claims. Ultimately, the jury returned a verdict in McGuire’s favor, finding that Neidig used unreasonable force against McGuire while acting under color of state law under Section 1983, and that Neidig was liable for McGuire’s assault and battery claims as well. The issue this case presented for the Pennsylvania Supreme Court's review involved whether the City of Pittsburgh had a statutory duty to indemnify one of its police officers for the judgment entered against him in a federal civil rights lawsuit. The Supreme Court rejected the argument that a federal jury’s finding that a police officer acted “under color of state law” for purposes of Section 19831 necessarily constituted a “judicial determination” that he also acted within the “scope of his office or duties” for purposes of the Political Subdivision Tort Claims Act. Thus, the judgment was affirmed. View "McGuire v. City of Pittsburgh" on Justia Law

Appellant Demetrius Coleman appealed a superior court order vacating his sentence, and remanding the case to the Allegheny County Court of Common Please for resentencing. The Superior Court concluded the sentencing court erred in failing to sentence Appellant pursuant to the mandatory sentencing enhancement set forth in Section 9715(a) of the Sentencing Code, 42 Pa. C.S. § 9715(a), requiring that any person convicted of third-degree murder “in this Commonwealth who has previously been convicted at any time of murder . . . be sentenced to life imprisonment.” The issue presented for the Pennsylvania Supreme Court's review was whether the Superior Court was correct in concluding that the mandatory sentencing enhancement applied to a defendant such as Appellant, who killed three people simultaneously and was thereafter convicted of three counts of third-degree murder. Upon careful review, the Supreme Court concluded the sentencing enhancement did apply in such a scenario. View "Pennsylvania v. Coleman" on Justia Law

A declaratory judgment action was filed in the context of two insurance- company liquidation matters. The parties asserted they informally agreed, among themselves, and the single Commonwealth Court Judge overseeing the cases, to a procedure for a three-judge panel of the Commonwealth Court to render a decision to be reviewable via exceptions by the Commonwealth Court, en banc. However, as the agreement was not memorialized as of record, the party aggrieved by the panel opinion, the statutory liquidator, lodged an immediate appeal with the Pennsylvania Supreme Court after that opinion and order were filed, and then filed exceptions with the Commonwealth Court, en banc. After the Commonwealth Court, en banc, rendered a second opinion and order, overruling the exceptions and confirming the panel’s initial decision, the statutory liquidator filed a second appeal with the Supreme Court parallel to the first. This raised a jurisdictional question. The Supreme Court found two of four petitions filed were properly dismissed for want of jurisdiction. The other two were properly before the Court, and on the merits, the Court affirmed the Panel's July 9, 2021 order: “[t]here is simply no statutory authority for this well-intentioned proposal [or] any standard to guide the Liquidator’s establishment [of the proposal] or [the Commonwealth Court’s] evaluation thereof.” View "In Re: American Network Ins. Co." on Justia Law

Four named appellants were convicted of what was codified in Pennsylvania as second-degree murder, and ineligible for parole per 61 Pa.C.S. § 6137(a)(1). Appellants petitioned for review at Commonwealth Court, seeking a declaration that Section 6137(a)(1) was unconstitutional as applied on the grounds that depriving Appellants of any opportunity for parole violated the Commonwealth and federal constitutions. The Pennsylvania Supreme Court granted review to determine whether this suit was within the Commonwealth Court’s original jurisdiction to hear suits against government agencies like the Board of Probation and Parole (“Board”) or whether the petition fell within the statutory exception for petitions in the nature of post-conviction relief. The Supreme Court affirmed the Commonwealth Court’s holding that it lacked jurisdiction. View "Scott v. Board of Probation and Parole" on Justia Law

The Pennsylvania Supreme Court granted allocatur review in this case to determine whether the Commonwealth waived reliance on the doctrine of inevitable discovery where its Concise Statement of Matters Complained of on Appeal asserted only that the trial court erred in granting a motion to suppress filed by Appellant Nathanial Price because the affidavit of probable cause at issue failed to assert probable cause sufficient for the issuance of a warrant. Specifically, the Court addressed whether, under these circumstances, the doctrine of inevitable discovery constituted a “subsidiary issue” to the issue of the sufficiency of probable cause under Pa.R.A.P. 1925(b)(4)(v) and was thus not waived by operation of Pa.R.A.P. 1925(b)(4)(vii). Concluding that it was not a subsidiary issue and thus not preserved for review by the Superior Court, the Supreme Court vacated that court’s order. View "Pennsylvania v. Price" on Justia Law

Child K.N.L. (born 2010) was adjudicated dependent and committed to the custody of the Philadelphia Department of Human Services (DHS) in 2015. The parental rights of the child’s biological parents were terminated involuntarily in 2017. The juvenile court vacated the custodial and visitation rights of the child’s former caregiver, R.B.P., who had been the legal guardian at the time she entered foster care. In 2018, with the support and consent of DHS, the child’s foster parent filed a report of intention to adopt and petition to adopt the child. Prior to the finalization, the child’s biological maternal aunt, D.M., moved to intervene in the adoption matter as well as her own petition to adopt the child. Appellant T.B., the adult child of the former guardian R.P.B., also sought to intervene and to adopt the child. The child was removed from the pre-adoptive foster home and the foster parent requested to withdraw her pending adoption petition. The Pennsylvania Supreme Court accepted review of this matter to determine whether the juvenile court erred when it denied appellant standing — based on in loco parentis status — to intervene in the adoption of the child, and concluded the juvenile court did err. The court interpreted and applied relevant Adoption Act provisions strictly, as principles of limitation on standing in an adoption action, in contravention of 23 Pa.C.S. §2312 and the applicable case law, rather than assessing whether appellant demonstrated a genuine and substantial interest in having a formal, permanent parental role in the child’s life as a result of the in loco parentis status he pleaded. " The Supreme Court remanded this case to the adoption court to consider appellant's standing anew in light of the proper standards. View "In the Int. of: K.N.L." on Justia Law

This appeal presented the issue of whether Section 7403(e) of the Pennsylvania Mental Health Procedures Act (“MHPA”), 50 P.S. § 7403(e), authorized a trial court to dismiss criminal charges filed against a defendant who was incompetent, and would likely remain so, under circumstances where the passage of time and its effect upon the criminal proceedings render it unjust to resume the prosecution. Following established intermediate appellate court precedent, the Superior Court held that Section 7403(e) authorized dismissal of criminal charges only under circumstances where the defendant regained his competence, and not where he remained incompetent. Appellant Jquan Humphrey challenged this interpretation. After its review, the Pennsylvania Supreme Court rejected the Superior Court’s interpretation of Section 7403(e) and held that the MHPA did not limit the trial court’s authority to dismiss criminal charges to circumstances where the defendant regained his competency. "Instead, Section 7403(e) authorizes a trial court to dismiss criminal charges filed against an incompetent defendant where the court finds that it would be unjust to resume the prosecution due to the passage of time and its effect upon the criminal proceeding." Accordingly, the Supreme Court vacated the judgments of the Superior Court and remanded for further proceedings. View "Pennsylvania v. Humphrey" on Justia Law

In an appeal by allowance, the Pennsylvania Supreme Court considered whether the unwanted kissing of a person’s neck constituted the touching of “sexual or other intimate parts” for purposes of the crime of indecent assault. The Court determined that “other intimate parts” were those parts of the body that were personal and private, and which a person ordinarily allows to be touched only by other individuals with whom the person has a close personal relationship, and which are commonly associated with sexual relations or intimacy. Applying this meaning, the Court concluded that the neck was an intimate part of the body, and thus, it did not disturb the jury’s finding that Appellant Carl Gamby, by grabbing the victim, K.A., from behind and kissing her neck for the purpose of sexual gratification, committed indecent assault. View "Pennsylvania v. Gamby" on Justia Law