Justia Pennsylvania Supreme Court Opinion Summaries

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

The jury in this medical malpractice case awarded plaintiff Karen Cowher a lump sum amount of damages under the Pennsylvania Survival Act, and did not itemize the amount of pain and suffering damages or other components of its aggregate award. The Superior Court granted the defendants Dr. Sobhan Kodali, St. Luke’s University Health Network, and St. Luke’s Cardiology Associates a new trial on survival damages based on their claim the admission of plaintiff’s expert opinion testimony on pain and suffering was erroneous. The narrow question the Pennsylvania Supreme Court addressed in this appeal was whether defendants waived their right to a new trial under the general verdict rule. This rule applies and mandates waiver when a general verdict rests upon both valid and invalid grounds, and the litigant challenging the verdict failed to request a special verdict slip that would have clarified the basis for the verdict. The Supreme Court concluded these were the circumstances here. Accordingly, the Supreme Court held defendants waived a new trial under the general verdict rule and reversed the Superior Court’s order for a new trial. View "Estate of Cowher. v. Kodali, et al" on Justia Law

The underlying dispute before the Pennsylvania Supreme Court in this case involved the adequacy of state funding for community participation support ("CPS") services, which were designed to help individuals with autism or intellectual disabilities live independently. The primary issue on appeal related to the exhaustion requirement. The Pennsylvania Department of Human Services ("DHS") issued ODP Announcement 19-024, indicating it intended to change the rate structure for CPS services provided under the Home and Community Based Services (“HCBS”) waivers. Petitioners filed an action for declaratory and injunctive relief, challenging the legality of the new fee schedule and alleged the new reimbursement rates were too low to sustain the provision of CPS services to eligible recipients. Pertinent here, the Commonwealth Court agreed with one of DHS' preliminary objections that Petitioners failed to exhaust their administrative remedies, as required by case precedent, before seeking judicial review. The court acknowledged a narrow exception to the exhaustion requirement whereby a court may consider the merits of a claim for declaratory or injunctive relief if a substantial constitutional question is raised and the administrative remedy is inadequate. It clarified, however, that the exception only applied where the plaintiff raises a facial constitutional challenge to the statute or regulation in question, as opposed to its application in a particular case. Here, the court concluded, the Petitioners were attacking the fee schedule in the Final Notice, which was produced by application of the legal authority cited in that notice, and not advancing a facial constitutional challenge. The court also found Petitioners failed to demonstrate the administrative remedy was inadequate. The Supreme Court affirmed the Commonwealth Court’s order insofar as it sustained the preliminary objection asserting that the Petitioners failed to exhaust their administrative remedies, and dismissed the Petition as to those parties. The order was vacated in all other respects, and the matter was remanded for further proceedings. View "Rehabilitation & Community Providers Association, et al. v. Dept. Human Svcs" on Justia Law

A trial court found Appellant Victor Stevenson guilty of indirect criminal contempt for violating a final order issued pursuant to the Protection from Abuse (“PFA”) Act. On appeal to the Superior Court, Appellant argued that the evidence of record was insufficient to support his conviction because the Commonwealth failed to present adequate proof that he received proper notice of the final PFA order from a member of law enforcement or a person tasked by the trial court to provide such notice. The Superior Court rejected this argument, holding that the subject of a final PFA order had to have notice of the order to be found guilty of indirect criminal contempt for violating the order but that it was unnecessary for a member of law enforcement or a person designated by the court to provide that notice. Finding no reversible error, the Pennsylvania Supreme Court affirmed the Superior Court. View "Pennsylvania v. Stevenson" on Justia Law

On the morning of May 27, 2016, the body of Denhad Taiedi, who owned the Jefferson Hills Motel, was discovered in the motel’s office with a fatal gunshot wound to the head. Blood stains were found on a tray inside a cash box, inside a bank bag, and on the office door, and a trail of fresh blood drops led from the motel office to the parking lot. Testing of the blood revealed that it matched Appellant Derrick Gallaway’s DNA, and, on August 26, 2016, a warrant was issued for his arrest. When officers were unable to locate Appellant at any of his known addresses, his information was entered into the National Crime Information Center (“NCIC”). More than a year later, Appellant was arrested in Carmichael, California, and he was extradited to Pennsylvania on or around December 13, 2017. On the third and final day of trial, the Commonwealth sought and was granted permission to play for the jury an edited version of Appellant’s videotaped interview by police detectives. The edited version of the videotaped interview was approximately 17 minutes long, and clearly showed Appellant in bright red prison clothing throughout. The Commonwealth asserted that the videotape evidenced Appellant’s consciousness of guilt, as it showed him making false statements to police regarding, inter alia, whether he was in Pittsburgh at the time the Victim was killed, whether he had ever stayed at the motel, and whether he knew two testifying witnesses. In this appeal by allowance, the issue this case presented for the Pennsylvania Supreme Court's consideration was whether the Superior Court’s determination that the probative value of videotape evidence which showed Appellant in prison clothing outweighed its prejudicial effect, such that admission of the evidence did not deprive Appellant of a fair trial under Estelle v. Williams, 425 U.S. 501 (1976). To this, the Court held that the probative value of the evidence was not outweighed by its prejudicial effect, and, thus, it affirmed Appellant’s judgment of sentence. View "Pennsylvania v. Gallaway" on Justia Law

In this appeal, the issue presented for the Pennsylvania Supreme Court's review was whether Appellant, Wilkinsburg School District, was required to obtain prior approval from the Department of Education before changing the mode of transportation for charter school students, from school buses to public transportation. After review of the governing statutes and administrative regulations promulgated by the State Board of Education, the Supreme Court concluded the District was not required to obtain such approval and, therefore, reversed the Commonwealth Court decision and remanded to that court for further proceedings. View "Bell, et al. v. Wilkinsburg Sch. Dist." on Justia Law