Justia Pennsylvania Supreme Court Opinion Summaries

William Roberts was convicted of statutory sexual assault, sexual assault, corruption of the morals of a minor, and indecent assault in 2005. He was sentenced to one and a half to three years in prison and required to register as a sexual offender for life under Megan’s Law III. Roberts complied with his registration obligations until 2019 but failed to report in 2020. The Pennsylvania State Police (PSP) discovered that Roberts no longer lived at his registered address and had not updated his information, leading to his arrest and charges for failing to comply with registration requirements.The Court of Common Pleas of Fayette County convicted Roberts of two counts of failure to comply with registration requirements and sentenced him to five to ten years in prison. Roberts appealed, arguing that the Commonwealth failed to prove he knew he was required to register. The Superior Court affirmed the conviction, holding that the crime occurred when Roberts knowingly failed to register or verify his residence, regardless of whether he knew he was required to do so.The Supreme Court of Pennsylvania reviewed the case to determine if the Commonwealth must prove that a sexual offender knew of their registration obligations to convict them of failure to comply. The Court held that the Commonwealth must prove the offender knew of their SORNA obligations. However, the Court found sufficient evidence that Roberts knew of his lifetime registration requirement, as he had signed forms acknowledging this multiple times. Thus, the Supreme Court affirmed the judgment of sentence. View "Commonwealth v. Roberts" on Justia Law

On May 8, 2020, Sergeant Aaron Scott and Officer Samuel Greco of the Frazer Township Police Department responded to a rollover vehicle accident. They found Jarren Crosby and a female companion near the overturned vehicle. Crosby admitted to driving, and the officers detected signs of marijuana use. Crosby was unsteady and had slurred speech. When the officers detained him for a DUI investigation, Crosby became agitated and resisted arrest. Officer Greco attempted to handcuff Crosby, who resisted by pulling away and screaming. Greco then tackled Crosby and used a taser to subdue him. Crosby was charged with multiple offenses, including DUI and resisting arrest.The Court of Common Pleas of Allegheny County convicted Crosby of DUI, resisting arrest, and careless driving, while acquitting him of other charges. Crosby was sentenced to four days in the DUI Alternative to Jail Program and fifteen months’ probation. Crosby’s post-sentence motions were denied, and he appealed, challenging the sufficiency of the evidence for his resisting arrest conviction.The Superior Court of Pennsylvania affirmed the trial court’s judgment, holding that the evidence was sufficient to support Crosby’s conviction for resisting arrest. The court noted that Crosby’s resistance required substantial force to overcome, as Officer Greco had to tackle him and use a taser.The Supreme Court of Pennsylvania reviewed the case and affirmed the Superior Court’s decision. The court clarified that the offense of resisting arrest under the second variant of the statute involves the defendant employing means that justify or require substantial force to overcome the resistance. The court held that Officer Greco’s tackle of Crosby constituted substantial force, and thus, the evidence was sufficient to support Crosby’s conviction for resisting arrest. The judgment of the Superior Court was affirmed, and the case was remanded to correct a scrivener’s error in the sentencing order. View "Commonwealth v. Crosby" on Justia Law

A law firm, Kleinbard LLC, provided legal services to the Lancaster County District Attorney's Office, led by then-District Attorney Craig Stedman, to challenge the county commissioners over the use of certain forfeiture assets. Stedman and Kleinbard signed an engagement letter, agreeing that Kleinbard would be compensated for its services. The commissioners, however, refused to pay Kleinbard's invoices exceeding the $5,000 budgeted for legal services, arguing that the additional expenses were unauthorized.The Lancaster County Court of Common Pleas sustained preliminary objections from the defendants, allowing only the $5,000 payment and dismissing the remaining claims. The court ruled that the contract for legal services exceeding the budgeted amount was unenforceable under the County Code, which prohibits contracts that exceed appropriated sums without commissioners' approval.The Commonwealth Court affirmed the lower court's decision, agreeing that Stedman lacked authority to enter into a contract exceeding his budget without commissioners' approval. The court also expressed uncertainty about the nature of the Program Accounts, which Kleinbard claimed were controlled by the District Attorney and funded by program participants, not taxpayer money.The Supreme Court of Pennsylvania reviewed the case and found that the lower courts erred by not accepting as true the well-pleaded facts in Kleinbard's complaint at the preliminary objections stage. The Supreme Court held that the allegations, if true, established that the Program Accounts were not subject to the County Code's appropriation limits. Therefore, the court reversed the Commonwealth Court's decision and remanded the case for further proceedings to determine the nature and control of the Program Accounts. View "Kleinbard, LLC v. Lancaster Co. DA" on Justia Law

Prospect Crozer, LLC owned and developed 57.7 acres of real property in Upland Borough, Delaware County, assessed at $80,166,493 for tax years 2017-2019. Prospect appealed the assessment, but the Delaware County Board of Assessment Appeals denied it. Prospect then appealed to the Delaware County Court of Common Pleas, where the Chester Upland School District intervened. Senior Judge John L. Braxton, assigned by the Pennsylvania Supreme Court, presided over the de novo tax assessment proceedings. During this time, Judge Braxton was appointed to the Philadelphia Board of Revision of Taxes and received his first payment from the Board on June 16, 2019. He continued to preside over the tax appeals and issued orders in October 2019.The Delaware County Court of Common Pleas conducted a hearing to determine the timeline of Judge Braxton's dual service and found that he began receiving compensation from the Board on June 16, 2019. The Commonwealth Court then vacated the orders issued by Judge Braxton, concluding that his simultaneous service on the Board and as a judge violated Article V, Section 17(a) of the Pennsylvania Constitution, which prohibits judges from holding an office or position of profit in the government. The court held that this violation resulted in the automatic forfeiture of his judicial office, rendering the orders legal nullities.The Supreme Court of Pennsylvania reviewed the case and agreed that Judge Braxton violated Section 17(a) by holding a position of profit with a municipal corporation while serving as a judge. However, the court rejected the Commonwealth Court's conclusion that this violation resulted in the automatic forfeiture of his judicial office. Instead, the Supreme Court held that the violation created a constitutionally impermissible conflict of duties, requiring the vacatur of the orders entered in the tax appeals. The case was remanded to the Delaware County Court of Common Pleas for reassignment to a new judge. View "In re: Appeal of Prospect Crozer LLC From the Decision of the Board of Assessment Appeals of Delaware County, PA" on Justia Law

Derek Murchison was convicted of first-degree murder for the strangulation of Linda Willis on October 5, 2001, and sentenced to life in prison without parole. Murchison later sought post-conviction DNA testing of items found at the crime scene, arguing that the new DNA results constituted after-discovered evidence warranting a new trial.The Philadelphia County Court of Common Pleas dismissed Murchison's petition, and the Superior Court affirmed. The PCRA court found that the new DNA evidence was cumulative and would not likely compel a different verdict. The court noted that the jury had already been informed that Murchison's DNA was not found at the crime scene and still convicted him based on witness testimony and his confessions.The Supreme Court of Pennsylvania reviewed the case to determine if the lower courts applied the correct legal standard for after-discovered evidence claims based on post-conviction DNA testing. The court held that the same standard applies to all after-discovered evidence claims, including DNA evidence. The court concluded that the new DNA evidence did not establish Murchison's actual innocence and was not likely to result in a different verdict. The court affirmed the lower courts' decisions, emphasizing that the conviction was based on substantial witness testimony and Murchison's confessions, which were not undermined by the new DNA evidence. View "Commonwealth v. Murchison" on Justia Law

On November 18, 2020, Officer Matthew Ibbotson and his partner stopped a silver Honda with heavily tinted windows in a high-crime area of Philadelphia for traffic violations. The driver, Omar Saunders, made suspicious movements, and Officer Ibbotson saw the handle of a gun under the driver’s seat. Saunders admitted he did not have a permit for the gun, which was later found to be stolen. Saunders was arrested, and the gun was seized.The Court of Common Pleas of Philadelphia County denied Saunders’s motion to suppress the gun, ruling that the seizure was justified under the plain view doctrine and the automobile exception, which requires both probable cause and exigent circumstances. Saunders was convicted of firearms offenses and sentenced to three and a half to seven years in prison. The Superior Court affirmed the judgment, holding that the seizure was lawful under the plain view doctrine.The Supreme Court of Pennsylvania reviewed the case to determine the legality of the warrantless seizure. The court held that the seizure was constitutional under the plain view doctrine. It found that the police had a lawful vantage point, the incriminating nature of the gun was immediately apparent, and the police had a lawful right of access to the gun. The court emphasized that the unexpected development of probable cause during a lawful traffic stop justified the seizure without a warrant. Consequently, the court affirmed the Superior Court’s order upholding the denial of suppression of the firearm. View "Commonwealth v. Saunders" on Justia Law

The case involves a group of appellants, including individual citizens, CeaseFirePA, and the City of Philadelphia, who challenged two Pennsylvania statutes that prevent local governments from enacting their own firearms regulations. The appellants argue that these statutes, Section 6120 of the Pennsylvania Uniform Firearms Act and Section 2962(g) of the Home Rule Charter and Optional Plans Law, hinder their ability to address gun violence effectively at the local level.The Commonwealth Court previously reviewed the case and dismissed the appellants' petition, sustaining preliminary objections for failure to state a claim. The court found that the appellants did not sufficiently allege violations of substantive due process under Article I, Section 1 of the Pennsylvania Constitution, the state-created danger doctrine, or improper interference with Philadelphia's delegated duties under the Local Health Administration Law and the Disease Prevention and Control Law of 1955.The Supreme Court of Pennsylvania reviewed the case and affirmed the Commonwealth Court's decision. The court held that the appellants failed to identify a constitutionally protected right that the statutes infringed upon, thus failing to establish a substantive due process claim. The court also concluded that the appellants did not meet the elements required to establish a state-created danger claim, particularly the requirement that the harm caused was foreseeable and fairly direct. Lastly, the court determined that the statutes did not interfere with Philadelphia's delegated public health responsibilities, as the relevant laws did not implicitly or explicitly authorize local firearm regulation.In summary, the Supreme Court of Pennsylvania affirmed the dismissal of the appellants' petition, upholding the statutes that preempt local firearm regulations. View "Crawford v. Commonwealth" on Justia Law

Alcatel-Lucent USA Inc. (Alcatel) challenged the constitutionality of Pennsylvania's 2014 cap on net-loss carryover (NLC) deductions for corporate net income (CNI) tax. The cap allowed corporations to carry forward net operating losses up to the greater of $4 million or 25% of the company's 2014 net income. Alcatel, with a net income of $27,332,333 and accumulated losses exceeding that amount, could only carry over $6,833,083 due to the cap, resulting in a taxable income of around $20 million and a tax liability of approximately $2 million. Alcatel paid the tax and sought a refund, arguing the cap violated the Uniformity Clause of the Pennsylvania Constitution.The Department of Revenue's Board of Appeals and the Board of Finance and Revenue denied Alcatel's refund request, citing lack of authority to decide constitutional issues. Alcatel then appealed to the Commonwealth Court, which initially affirmed the Board's decision, applying the Chevron test and concluding that the Nextel decision should not apply retroactively. However, after the Pennsylvania Supreme Court's decision in General Motors Corp. v. Commonwealth, which held that Nextel applies retroactively, an en banc panel of the Commonwealth Court reversed the earlier decision, sustaining Alcatel's exceptions and ordering a refund.The Supreme Court of Pennsylvania reviewed the case and concluded that the General Motors decision was erroneous. The Court held that Nextel should apply only prospectively, not retroactively, as it established a new principle of law. The Court applied the Chevron test, determining that retroactive application would not further the operation of the rule and would cause significant financial harm to the Commonwealth. Consequently, the Court reversed the Commonwealth Court's decision, ruling that due process does not require the Commonwealth to refund the taxes paid by Alcatel in 2014. View "Alcatel-Lucent USA Inc. v. Commonwealth" on Justia Law

Michael Jones was convicted of attempted murder and related charges after an incident where he and his codefendants, Syheed Wilson and Keirsten Carroll, were involved in a shooting of a cab driver, Alex Destin. Jones directed the cab driver and then shot him, while Wilson also shot the driver. The three were identified through surveillance footage and arrested. Wilson gave a statement to the police implicating Jones as the shooter.At trial, Jones objected to the admission of Wilson’s statement, arguing it violated the Sixth Amendment Confrontation Clause as established in Bruton v. United States. The trial court overruled the objection, and the jury was instructed to consider each defendant’s statement only against the one who made it. Jones was found guilty on all counts and sentenced to twenty to forty years in prison. The Superior Court affirmed the conviction, reasoning that the redacted statement, which referred to Jones as “my friend,” did not violate the Confrontation Clause because it did not explicitly name him and required linkage with other evidence to be incriminating.The Supreme Court of Pennsylvania reviewed the case, focusing on whether the admission of Wilson’s redacted statement violated Bruton. The court noted that the statement, though redacted to refer to Jones as “my friend,” still directly incriminated him by describing him in a way that the jury could easily identify him, especially since the jury was shown surveillance footage and still images identifying Jones. The court concluded that the statement violated Bruton’s prohibition against admitting a non-testifying codefendant’s confession that directly implicates the defendant.The Supreme Court of Pennsylvania vacated the Superior Court’s order and remanded the case for the Superior Court to determine whether the Bruton violation amounted to harmless error. View "Commonwealth v. Jones" on Justia Law

The case involves a petition challenging the public release of a grand jury report by the 30th County Investigating Grand Jury. The petitioner argued that the report did not meet the statutory definition of an "investigatory grand jury report" under the Investigatory Grand Jury Act (IGJA) and that the supervising judge erred in ordering its release. The petitioner also contended that the report's criticism of named, unindicted individuals violated their due process rights and the fundamental right to reputation under the Pennsylvania Constitution.The Philadelphia County Court of Common Pleas initially accepted the report and ordered its public release. The supervising judge provided notice and an opportunity to respond to some, but not all, named, unindicted individuals criticized in the report. The petitioner, along with others, sought to have the report permanently sealed or redacted. The supervising judge made some redactions but ultimately ordered the report to be unsealed.The Supreme Court of Pennsylvania reviewed the case and concluded that the report did not satisfy the IGJA's definition of an "investigatory grand jury report" because it neither related to organized crime or public corruption nor proposed recommendations for legislative, executive, or administrative action in the public interest. The court found that the report focused on punishing specific individuals and providing answers to the deceased-accused's family, rather than addressing broader public concerns.The court also determined that due process requires notice and an opportunity to respond for all named, unindicted individuals criticized in a grand jury report. The supervising judge's failure to provide such notice to all criticized individuals was deemed an error. Consequently, the Supreme Court vacated the supervising judge's order and remanded the case with instructions to permanently seal the report. View "In Re: The Thirtieth County Investigating Grand Jury" on Justia Law