Justia Pennsylvania Supreme Court Opinion Summaries

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

Appellant Paul Taylor appealed the denial of his fifth petition for post-conviction relief. In 1991, Taylor brutally murdered his wife, two of his minor children, his mother-in-law, and his mother-in-law’s minor son. Taylor pled guilty to five counts of criminal homicide generally. Following a degree-of-guilt hearing, the trial court convicted Taylor of first-degree murder on all five counts. The matter proceeded to a penalty phase hearing, following which the trial court determined that the imposition of the death penalty was appropriate for four of Taylor’s murder convictions and that a penalty of life imprisonment was appropriate for the remaining murder conviction. The trial court formally imposed Taylor’s sentences on January 23, 1992. Petitioner premised his fourth PCRA petition upon the well-publicized scandal involving the exchange of inappropriate emails between employees of the OAG and members of the judiciary, including former Justices Eakin and McCaffery. Petitioner alleged that emails exchanged during the pendency of "Taylor IV" reflected partiality on the part of the Pennsylvania Supreme Court in disposing of his appeal, in violation of Taylor’s due process rights. The PCRA court dismissed Taylor’s fourth petition, concluding that the PCRA court lacked the authority to grant the relief that Taylor sought. Taylor then appealed. On November 6, 2019, with its participating members being equally divided on the matter, the Pennsylvania Supreme Court affirmed the PCRA court’s order by operation of law. In his fifth PCRA petition, Appellant reasserted his due process claim premised upon the alleged partiality of the Supreme Court in Taylor IV arising out of the email scandal, as well as a request for a new appeal in that matter nunc pro tunc. The Supreme Court agreed with the conclusion of the PCRA court that Appellant untimely filed his fifth petition, therefore denial was affirmed. View "Pennsylvania v. Taylor" on Justia Law

In this discretionary appeal, the issue presented for the Pennsylvania Supreme Court's review centered on whether certain life insurance and individual retirement account (IRA) proceeds that Johanna Goodwin (Wife) acquired as sole beneficiary prior to the dissolution of her marriage to Scott Goodwin (Husband) fell within the purview of Section 3501(a)(3) of Pennsylvania's Divorce Code. The Supreme Court held that, under the circumstances presented here, such proceeds constituted “gifts” as the term was used in Section 3501(a)(3), and, thus, they were excluded from the marital estate for equitable distribution purposes. Because the Superior Court reached the same conclusion, the judgment of that court was affirmed. View "Goodwin v. Goodwin" on Justia Law

Charlestown Township, Chester County, Pennsylvania, enacted a zoning ordinance that permitted outdoor billboards in a particular district. A statewide regulation concerning roadside billboards promulgated by the Pennsylvania Department of Transportation (“PennDOT”) had the practical effect of barring that use. Charlestown Outdoor, LLC, (“Outdoor”) sought nonetheless to erect a billboard on property it leased in that zoning district. In pursuit of that objective, Outdoor filed a substantive-validity challenge to Charlestown Township’s ordinance, asserting that it was de facto exclusionary. The Pennsylvania Supreme Court found it wasn't the zoning ordinance, but rather the statewide regulation, that precluded the proposed use. Accordingly, the Supreme Court held that the challenged zoning ordinance was not de facto exclusionary. It therefore affirmed the Commonwealth Court’s rejection of Outdoor’s validity challenge. View "In Re Charlestown Outdoor, LLC" on Justia Law

In 2008, Act 129 amended the Pennsylvania Electricity Generation Customer Choice and Competition Act for the purpose of promoting an energy efficiency and conservation (“EE&C”) program in Pennsylvania. This case centered around a provision in Act 129 that directed electric distribution companies (“EDCs”) in the Commonwealth to “furnish” smart electric technology to their customers. Several electric customers instituted legal action against the Public Utility Commission (“PUC”) to prevent the installation of smart meters at their homes. They contended a customer had the ability to opt-out of the installation of smart meters by EDCs. They also claimed that smart meters caused health problems and their installation constituted unsafe or unreasonable service under Section 1501 of the Public Utility Code. The Pennsylvania Supreme Court concluded Act 129 indeed mandated that EDCs furnish smart meters to all electric customers within an electric distribution service area and did not provide electric customers the ability to opt out of having a smart meter installed. An electric customer with concerns about smart meters may seek an accommodation from the PUC or EDC, but to obtain one ,the customer must establish by a preponderance of the evidence that installation of a smart meter violated Section 1501. In this case, the Court held the electric customers did not prove that installation of a smart meter at their premises violated Section 1501; therefore, the PUC was not required to prescribe any remedial action. Having so concluded, the Court reversed the Commonwealth Court’s ruling that Act 129 did not mandate the installation of smart meters. Additionally, the Supreme Court clarified the use of the conclusive causal connection standard for proving a violation under Section 1501 and held that a preponderance of the evidence was the standard that applied to claims brought under Section 1501. View "Povacz, et al. v. PUC, et al." on Justia Law

Appellant Albert Reid was convicted by jury on two counts of first-degree murder for the killings of his estranged wife, Carla Reid, and her fourteen-year-old daughter, D.M. He received two death sentences, and the Pennsylvania Supreme Court affirmed the judgment of sentence. Appellant subsequently filed a petition pursuant to the Post Conviction Relief Act (“PCRA”). The PCRA court denied the petition, and Appellant appealed to the Supreme Court, which affirmed in part the PCRA court’s order but remanded, while retaining jurisdiction, directing the PCRA court to provide a supplemental opinion addressing: why it denied relief on the whether appellant was incompetent to proceed to trial and represent himself; and whether prior counsel was ineffective for failing to investigate and effectively this issue before trial and for failing to raise it on appeal. Upon return from the PCRA court to the Supreme Court, the Supreme Court found the PCRA court erred in the manner in which it assessed Appellant’s claim that he was incompetent to stand trial, as the court’s reasoning, inter alia, failed to account for new, post-conviction evidence that potentially demonstrated that Appellant was incompetent to stand trial. Accordingly, the Court vacated in part the PCRA court’s order and remanded for further proceedings. View "Pennsylvania v. Reid" on Justia Law

Pennsylvania’s Public Employee Pension Forfeiture Act (“Act 140”) mandated the forfeiture of the pension of a public official or public employee when he or she was convicted of certain Pennsylvania crimes related to public office or public employment, or was convicted of federal offenses that were “substantially the same” as the forfeit-triggering state crimes. The Pennsylvania Supreme Court granted discretionary review to consider whether a federal conviction for false statements to a federal agent, 18 U.S.C. § 1001 was “substantially the same” as the Pennsylvania crime of false reports to law enforcement authorities, 18 Pa.C.S. § 4906, for purposes of Act 140. The Supreme Court concluded that the two offenses were not “substantially the same,” and, thus, the Commonwealth Court erred in affirming the forfeiture of the pension of Appellant, former Municipal Court of Philadelphia County Judge Joseph O’Neill. View "O'Neill v. SERS" on Justia Law

The Pennsylvania Supreme Court granted discretionary review to consider whether Pennsylvania Rule of Criminal Procedure 706(C) required a trial court to consider a defendant’s ability to pay prior to imposing mandatory court costs at sentencing. In 2015, appellant Alexis Lopez entered a negotiated guilty plea to possession with intent to deliver a controlled substance. The trial court sentenced him to eleven and one-half to twenty-three months’ imprisonment, followed by three years’ probation. Six months later, the trial court granted Lopez’s motion for early release on parole. Thereafter, Lopez violated the terms of his supervision three times. Prior to resentencing for his third violation, Lopez filed a “Motion for Ability-to-Pay Hearing at Sentencing to Waive Costs.” His motion contended “Pennsylvania statutes and the Rules of Criminal Procedure require that this [c]ourt consider [his] ability to pay and waive court costs due to his indigence and the burden the costs would impose on him.” The Supreme Court found that Rule 706(C) did not have a requirement as Lopez suggested, and affirmed the Superior Court. View "Pennsylvania v. Lopez" on Justia Law