Justia Pennsylvania Supreme Court Opinion Summaries

At issue before the Pennsylvania Supreme Court in this case centered on a determination of Appellant Manheim Township School District (“School District”) that one of its students, Appellee J.S., made terroristic threats to another student through social media – outside of the school day and off school property – substantially disrupting the school environment, and leading to his expulsion. The Supreme Court granted review to consider whether the School District denied J.S. due process during the expulsion process and to consider the proper standard by which to determine whether J.S. engaged in threatening speech unprotected under the First Amendment of the United States Constitution, or created a substantial disruption of the school environment. The Court determined J.S. did not engage in unprotected speech, and did not cause a substantial disruption to the school environment. Therefore, the Court concluded that the School District improperly expelled J.S., and affirmed the order of the Commonwealth Court. View "J.S., et al. v. Manheim Twp. SD" on Justia Law

The Pennsylvania Supreme Court granted review to determine whether the trial court erred by denying suppression of wireless internet network (WiFi) connection records obtained by police without a warrant from the Information Technology Department of Moravian College. At approximately 2:00 a.m. on February 2, 2017, two masked men posed as campus police to gain entry to the dorm room shared by Greg Farina and William Reilley in a dormitory building on the Moravian College Campus in Bethlehem. The men held Farina and Reilley at gunpoint and stole $1,000 and a jar of marijuana from Reilley’s footlocker. Reilley reported the robbery to campus officials around 11:00 a.m. and, thereafter, campus police requested that Moravian College’s Director of Systems Engineering, Christopher Laird, analyze its WiFi connection records to compile a list of students logged on to the WiFi in the dormitory building at the time of the robbery. Laird discovered only three Moravian College students were logged on to the campus WiFi at that location who did not reside in the building; two were females and the other was appellant, Alkiohn Dunkins. Campus police relayed this information to the Bethlehem Police Department. In the course of its investigation, detectives interviewed Reilley, appellant, and Colin Zarecki, another Moravian College student. Reilley told the detective he suspected appellant participated in the robbery because appellant previously stole from him by failing to pay for marijuana, while appellant denied being involved in the robbery and told police he had not entered the dormitory since October 2016. Zarecki told police that on the day after the robbery, appellant bragged to him about money he stole by posing as a campus police officer. Based on the above information, appellant was arrested and charged with robbery, conspiracy to commit robbery, receiving stolen property, and simple assault. The Supreme Court concluded the search of the WiFi records was constitutionally permissible, and accordingly, affirmed the superior court. View "Pennsylvania v. Dunkins" on Justia Law

Jonathan Peters (Claimant) was employed by Cintas Corporation (Employer) as a uniform sales representative. In this position Claimant worked half-days in Employer’s Allentown, Pennsylvania branch office on Mondays, Tuesdays, and Wednesdays, and traveled the remainder of those days, as well as Thursdays and Fridays, to meet with, and present products to, potential customers in the region around Reading, Pennsylvania. Following his last sales appointment on February 27, 2015, Claimant attended an Employer-sponsored event at a pub in Allentown called the Tilted Kilt. After leaving the event Claimant was injured in a motor vehicle accident. Alleging that the motor vehicle accident occurred during the course of his employment with Employer, Claimant filed a claim petition seeking partial disability benefits from February 28, 2015 to April 2, 2015, and total disability benefits from April 3, 2015 onwards. Employer responded, specifically denying that Claimant was in the course of his employment at the time of the motor vehicle accident. In a November 2016 decision, the WCJ denied and dismissed Claimant’s claim petition. The WCJ explained that for his injuries to be compensable under the Act, Claimant had the burden of demonstrating that he was in the course of his employment with Employer at the time of the motor vehicle accident, which required him to show that he was actually engaged in the furtherance of Employer’s business or affairs at the time of the accident. The WCJ wrote that he did not doubt that work was discussed at the event but that work-related discussions do “not transform every meeting into a business meeting.”Claimant then appealed to the Commonwealth Court, which affirmed. The Pennsylvania Supreme Court reversed, finding Claimant remained in the course of his employment through the event at the Tilted Kilt. Judgment was reversed and the matter remanded for further proceedings. View "Peters v. WCAB" on Justia Law

In 2015, Pittsburgh City Council passed Ordinance 2015-2062. The Ordinance supplemented Section 659.03 of the Pittsburgh Code of Ordinances, which already barred various forms of discrimination in housing. In early 2016, the Apartment Association of Metropolitan Pittsburgh (“the Association”), a nonprofit corporation comprising over 200 residential property owners, managers, and landlords, filed in the Allegheny County Court of Common Pleas a Complaint for Equitable Relief and Request for Declaratory Judgment against the City, alleging that the Nondiscrimination Ordinance violated the Home Rule Charter ("HRC") and the Pennsylvania Constitution. The Association also sought a temporary stay of enforcement of the Ordinance, which the court granted. The parties submitted Stipulations of Fact and submitted the case for judgment on the pleadings (the City) or summary judgment (the Association). The trial court heard argument, and ultimately ruled in favor of the Association, declaring the Ordinance invalid. The Pennsylvania Supreme Court held that the HRC’s Business Exclusion precluded the Pittsburgh ordinance that proscribed source-of-income discrimination in various housing-related contexts. Accordingly, the Court affirmed the Commonwealth Court’s entry of judgment in favor of Apartment Association. View "Apt. Assoc. of Metro Pittsburgh v. City of Pittsburgh" on Justia Law

The issue this case presented for the Pennsylvania Supreme Court's review centered on whether the Commonwealth Court erred in concluding that Firearm Owners Against Crime (FOAC), Kim Stolfer, Joshua First, and Howard Bullock (collectively, Appellees) had individual and associational standing to challenge four of the City of Harrisburg’s ordinances regulating firearms: the Discharge, Parks, Lost/Stolen, and Minors Ordinances. The Supreme Court affirmed the Commonwealth Court because it concluded Appellees had standing to bring this declaratory judgment action before the City enforced the challenged ordinances against them. View "FOAC, et al. v. City of Harrisburg" on Justia Law

In 2006, Rose Rellick (decedent) purchased two certificates of deposit ("CDs") listing as co-owners herself, her sister appellee Betty Rellick, and the daughters of her deceased brother George, appellee Kimberly Vasil and appellant Sharleen Rellick-Smith. Prior to purchasing the CDs, Decedent executed powers of attorney designating Betty and Kimberly as her attorneys-in-fact. It purportedly was Decedent’s intention that, upon her death, the proceeds of the CDs be divided equally among Appellant and Appellees. However, prior to Decedent’s death, Appellees removed Appellant’s name from the CDs. In March 2013, subsequent to Decedent’s death, Appellees cashed the CDs, which were worth approximately $370,000, and divided the money between the two of them. In 2014, Appellant filed an action against Appellees, claiming they breached their fiduciary duties to Decedent by removing Appellant’s name from the CDs and refusing to pay her any of the proceeds. Appellees filed a timely response to the complaint, but, relevant to this appeal, did not raise any affirmative defenses therein. Four months later, Appellees moved to dismiss the complaint, arguing that Appellant lacked standing and that her claim was barred by the statute of limitations. Appellees’ motion was ultimately granted on the basis that Appellant lacked standing. Notably, however, the trial judge determined that Appellees waived the statute of limitations defense by failing to raise it as a new matter in their answer, as required by Pa.R.C.P. 1030(a). The issue this case presented for the Pennsylvania Supreme Court's review was whether the Superior Court erred in affirming an order of the trial court that permitted the appellees to file an amended answer to include the affirmative defense of statute of limitations, which a different trial court judge previously ruled was waived. The Supreme Court concluded the second trial judge’s order violated the coordinate jurisdiction rule in this regard, thus the Superior Court erred in affirming the second court's order. The Superior Court decision was reversed, the trial judge's order vacated in part, and the matter remanded to the trial court for further proceedings. View "Rellick-Smith v. Rellick, et al." on Justia Law

Appellant Aaron Bradley and Tanaya Nelson were involved in a romantic relationship. Nelson began attending a trade school, where she met Bruce Fox (“Victim”). The relationship between Nelson and Victim was friendly, but evidently, not romantic. The day before Victim’s murder, Appellant and Nelson went shopping. After about an hour after she was dropped off at a relative's house, Nelson realized she had missed approximately ten calls from Appellant. Nelson called Appellant back, and he began to question her about where she was and who she was with. Appellant took her phone, seeing a text from Victim that made him angry. When she retrieved her phone some time later, Nelson realized texts and call message logs had been deleted. The Commonwealth ultimately retrieved those deleted messages and logs, finding a number of messages and calls were sent from Nelson's phone when it was in Appellant's possession. Appellant was arrested and charged with first-degree murder, possessing an instrument of crime (“PIC”), and carrying a firearm on a public street in Philadelphia related to his involvement in the shooting death of Victim. A jury found Appellant guilty on all charges; he was sentenced to life and concurrent terms for the PIC and firearms offenses. Three PCRA petitions were dismissed, with the court concluding issues raised were without merit. With new counsel, Appellant attempted to move the Superior Court to remand his case to the PCRA court so that he could raise claims of ineffective assistance of counsel. This motion was denied, with the Superior Court explaining that Appellant waived his challenge to the adequacy of PCRA counsel's effectiveness under current law, and that he could not challenge PCRA counsel’s effectiveness on appeal. The Pennsylvania Supreme Court considered the procedure for enforcing the right to effective counsel PCRA proceeding. "All parties before us acknowledge that the current approach is inadequate, and that revisions are in order, but have offered differing viewpoints." The Supreme Court determined that, "indeed, an overhaul of the procedure to vindicate a petitioner’s right to effective PCRA counsel is appropriate," and adopted the approach outlined in this opinion. View "Pennsylvania v. Bradley" on Justia Law

Appellant T.W. appealed a superior court order affirming a court of common pleas order denying his motion to suppress physical evidence and adjudicating Appellant delinquent for unlawful possession of a controlled substance. Appellant’s arrest for unlawful possession of a controlled substance arose from a vehicle stop and a subsequent Terry frisk. Upon frisking Appellant, a police officer of the Philadelphia Police Department felt a hard object in Appellant’s left pants pocket. Fearing that the unknown object could be a weapon, the officer reached into Appellant’s pocket and removed the object. Appellant was arrested for possessing the object and a subsequent search incident to arrest led to the discovery of a controlled substance on Appellant’s person. Before trial, Appellant made a motion to suppress the physical evidence recovered from his person, arguing that the police officer exceeded the scope of a permissible Terry frisk by reaching into Appellant’s pocket and removing an object during the frisk. The Pennsylvania Supreme Court granted review in this matter to address the standards by which a police officer may remove an object from within a suspect’s clothing during a Terry frisk. The Court previously addressed this issue in Pennsylvania v. Taylor, 771 A.2d 1261 (Pa. 2001) (plurality). The Court's review in that case resulted in a plurality decision whereby the opinion announcing the judgment of the Court held that a police officer conducting a lawful Terry frisk could remove an object from within a suspect’s clothing if the officer has reasonable suspicion to believe that the object is a weapon. "In light of the fact that Taylor did not produce a majority opinion, we reexamine the issue anew." View "In the Interest of: T.W." on Justia Law

A majority of the taxable inhabitants of Highspire Borough, Pennslyvania (the “Coalition”) filed a petition seeking to be established as a school district independent from Steelton-Highspire School District (“SHSD”) for the sole purpose of having the new school district be absorbed into the neighboring Middletown Area School District (“MASD”). The Secretary of Education issued an opinion and order denying the transfer on the grounds that the academic benefits to be enjoyed by the transferring students did not outweigh the educational detriments imposed upon the students in the SHSD and MASD districts. In particular, the Secretary concluded that the transfer would undermine the financial stability of SHSD and put a strain on class size and facilities at MASD. On appeal, the Commonwealth Court reversed, taking issue with the Secretary’s consideration of finances and holding that the Secretary should have instead narrowly focused on the academic benefits that would be enjoyed by the transferring students. The Pennsylvania Supreme Court concluded that in this case, the Secretary properly considered financial impacts and appropriately focused on the quality of education for the students in all of the school districts associated with the proposed transfer. The Court therefore reversed the order of the Commonwealth Court and remanded for further proceedings. View "In Re: Appeal for Formation of Independent SD" on Justia Law

Augustus Ashton died in October 1951; his will created a trust to be funded by the residue of his estate for the benefit of his family members and certain charitable interests (the “Trust”). The will created eight separate fixed annuities benefitting designated family members; five of those annuities terminated pursuant to their terms. Appellant Elizabeth Reed, Ashton's grandniece, was one of three remaining beneficiaries, entitled to $2,400 annually irrespective of the size of the Trust’s corpus for the remainder of her life, and then any surviving children or grandchildren born during her lifetime would receive a portion of her $2,400 share. Every beneficiary was entitled to the Trust’s income rather than its principal. After the termination of fixed annuity payments to all named beneficiaries, the Trust would continue to fund scholarships at the University of Pennsylvania in perpetuity. PNC Bank ("PNC"), the successor trustee, generated a Fourth and Interim Accounting for the period 1983 and 2017. Among other matters, PNC set forth two requests for adjudication: (1) divide the Trust in two, with the first to be funded with $5 million and dedicated to the named beneficiaries' annuity payments and the second to be funded with the balance of the Trust's current assets dedicated to University scholarships; and (2) to increase its fee for administering the trust, based on a percentage of the market value of the Trust as of the previous month. In this appeal by allowance, the Pennsylvania Supreme Court considered whether a vested beneficiary of the Trust had standing to challenge the Trust’s administration where her benefit consisted of a fixed annuity, and the Trust corpus was sufficient to provide the benefit for many years. The Supreme Court reversed the superior court insofar as it held Appellant lacked standing to object to transactions contained in the Fourth Account, and to PNC's request for additional compensation. "Appellant, as beneficiary under the Trust, had an interest which was harmed if the transactions of PNC as documented in the Fourth Account were improper as is alleged, and that her interest was substantial, direct, and immediate. It was substantial because any duties Appellant claims were breached were not owed to the general public, but to the beneficiaries.... any harm to Appellant’s interest in the trust res was not remote or speculative." View "Trust Under Will of Ashton" on Justia Law